A Compliance Defense For The FCPA?

Law360, New York (June 15, 2012, 12:44 PM EDT) -- In late April 2012, the New York Times broke a front-page story about Wal-Mart and its potential exposure under the Foreign Corrupt Practices Act in Mexico. According to the Times, top executives at Wal-Mart de Mexico shut down an internal investigation of widespread bribery of local Mexican officials in 2005, only to revive it and disclose it to the U.S. Department of Justice in 2011 after learning about the New York Times' own investigation of the same bribery allegations. Putting aside difficult news cycles, what other...
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