Walmart Settlement's Lessons For Avoiding FCPA Prosecution

Law360 (August 27, 2019, 5:23 PM EDT) -- Walmart Inc.’s $282 million settlement to resolve a seven-year Foreign Corrupt Practices Act investigation is only a slap on the wrist for the retail giant with annual profits of more than $7 billion, and far less than the reported government’s original $1 billion demand.

With a deferred prosecution agreement for Walmart, the parent company, a severely circumscribed corporate monitor and not a single executive facing prosecution, Walmart emerges the clear winner. This is especially true given that the corporate activities that led to the case provide a perfect lesson in what not to do in the corporate compliance context.

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