Walmart's DOJ Deal Evinces New Corporate Monitoring Policy

Law360 (June 24, 2019, 3:17 PM EDT) -- In a significant departure from previous practice, the U.S. Department of Justice imposed a corporate monitor on a company even after the company engaged in extensive remedial measures and enhanced its compliance functions, but the DOJ also agreed to narrow the scope, obligations and term of the corporate monitorship in what is the most meaningful example yet of how the DOJ intends to implement its new policy on corporate monitors.

Background

On June 20, 2019, Walmart Inc. entered into a three-year nonprosecution agreement and Walmart’s wholly owned Brazilian subsidiary, WMT Brasilia SarL, entered into a plea agreement with the DOJ for violations of...

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