In the Matter of Walmart Inc.

Decisions and steps

1. 20 June 2019Order finds books and records and internal controls violations and orders disgorgement of US$119,647,735 and interest of US$25,043,437^S3

Claims this case bears on

• Partly supported77
  An Associated Press report of 21 April 2012, relaying a New York Times investigation, said Wal-Mart investigators in Mexico found hundreds of suspect payments totaling more than US$24 million and that the company ended its internal probe.
  Press report, 21 April 20126 records citedBribery
• Supported94
  The SEC said in June 2019 that Walmart allowed subsidiaries in Brazil, China, India and Mexico to use third-party intermediaries who made payments to foreign officials without reasonable assurances of FCPA compliance.
  Regulator statement, 20 June 20193 records citedBribery
• Supported88
  Walmart said on 20 June 2019 that its global resolution with the Justice Department and the SEC ended all FCPA-related investigations into the company and its subsidiaries, for a combined payment of US$282.7 million.
  Company statement, 20 June 20194 records citedCorporate status

Sources

1. S3Tier A Order Instituting Cease-and-Desist Proceedings, In the Matter of Walmart Inc., Release No. 86159US Securities and Exchange Commission. Regulator order. 20 June 2019.Describes the 2005 Mexico allegations and inquiry and finds books and records and internal controls violations only. It describes improper payments in India and Brazil as background and charges no anti-bribery violation.