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Supported

The cited record supports the material proposition.

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.

The global resolution ends all FCPA-related investigations or inquiries into Walmart and its subsidiaries
About
Walmart Inc.
Claim made by
Walmart Inc., company statement
Published
20 June 2019
Original
Walmart Reaches Agreements with the DOJ and the SEC to Resolve their FCPA Investigations
Evidence score
88 How it was scored
Last reviewed
25 October 2026

Why this label

The Justice Department release confirms a three-year non-prosecution agreement with Walmart and a guilty plea by WMT Brasilia on the same dayS4. It puts the criminal penalty at US$137 million and the SEC disgorgement at US$144 millionS4. The SEC order sets a total of US$144,691,172 and imposes no civil penalty in view of a DOJ fine of US$137,955,249S3. These add up to the company's figureS5. The DOJ notes Walmart did not voluntarily disclose the Mexico conductS4. No later US enforcement step on these matters was found in this review. The company statement is consistent with the official records.

Current procedural position

Non-prosecution agreement with a three-year term and WMT Brasilia guilty plea announced on 20 June 2019S4. SEC order entered the same dayS3. No later breach finding was found.

Record supporting the assessment

Walmart entered into a three-year non-prosecution agreement
S4 Tier A US Department of Justice, Walmart Inc. and Brazil-Based Subsidiary Agree to Pay $137 Million to Resolve Foreign Corrupt Practices Act Case, 20 June 2019
WMT Brasilia pleaded guilty today in connection with the resolution.
S4 Tier A US Department of Justice, Walmart Inc. and Brazil-Based Subsidiary Agree to Pay $137 Million to Resolve Foreign Corrupt Practices Act Case, 20 June 2019
Walmart has agreed to a combined payment of $282.7 million.
S5 Tier B Walmart Inc. (Form 8-K exhibit), Walmart Reaches Agreements with the DOJ and the SEC to Resolve their FCPA Investigations, 20 June 2019

Conflicting or limiting record

Walmart did not voluntarily disclose the conduct in Mexico
S4 Tier A US Department of Justice, Walmart Inc. and Brazil-Based Subsidiary Agree to Pay $137 Million to Resolve Foreign Corrupt Practices Act Case, 20 June 2019

Evidence score: 88 of 100

The score grades how well the record establishes this assessment. It is not a score of Walmart Inc.. Score = source authority + directness + corroboration + procedural accuracy + currency + reproducibility.

ComponentPointsMaxReason
Source authorityIs the source competent to establish the proposition?2730DOJ and SEC records confirm the company statement.
DirectnessDoes the source state the proposition or only discuss adjacent facts?1820The official records state the agreements and amounts directly.
CorroborationDo independent records support the same material point?1315DOJ, SEC and company documents agree on the amounts.
Procedural accuracyDoes the record settle the procedural state the claim describes?1315The agreements are final, but the DOJ release does not give a case number or the plea court record.
CurrencyHas the record been checked against later developments?810The NPA term has run, and no closing record was read.
ReproducibilityCan a reader locate the passage and repeat the assessment?910All three documents are public.
Total88100

Timeline

  1. Walmart announces the global resolutionS5
  2. DOJ announces NPA and WMT Brasilia pleaS4

Related cases

  • In the Matter of Walmart Inc.US Securities and Exchange Commission. Regulatory. Administrative Proceeding File No. 3-19207.Stage: Cease-and-desist order entered on consent on 20 June 2019.
    • Order finds books and records and internal controls violations and orders disgorgement of US$119,647,735 and interest of US$25,043,437S3
  • United States v. WMT Brasilia S.a.r.l. and non-prosecution agreement with Walmart Inc.US Department of Justice, Criminal Division Fraud Section and US Attorney's Office for the Eastern District of Virginia. Criminal. Not published.Stage: Non-prosecution agreement with a three-year term. WMT Brasilia pleaded guilty on 20 June 2019.
    • NPA with Walmart and guilty plea by WMT Brasilia, combined criminal penalty of US$137 millionS4

Responses

  • Walmart Inc., 20 June 2019: Walmart said it was pleased to resolve the matter and had spent more than US$900 million on FCPA inquiries over seven years.S5

Revision history

  • Assessment first published with label Supported.

Have a record that changes this assessment? See corrections and responses.

Sources

  1. S4Tier A Walmart Inc. and Brazil-Based Subsidiary Agree to Pay $137 Million to Resolve Foreign Corrupt Practices Act CaseUS Department of Justice. Regulator press release. 20 June 2019.Supports the NPA, the WMT Brasilia plea and the penalty. It does not give a case number.Link working, checked 25 October 2026
  2. S5Tier B Walmart Reaches Agreements with the DOJ and the SEC to Resolve their FCPA InvestigationsWalmart Inc. (Form 8-K exhibit). Company statement. 20 June 2019.Company's account of the resolution and payment total. It makes no statement on the 2012 allegations.
  3. 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.

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