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.

Why this label

The SEC release states the proposition in its own words^S2. The order itself finds that the four subsidiaries operated without sufficient anti-corruption internal accounting controls and cites the books and records and internal controls provisions^S3. The order was entered on Walmart's offer of settlement, and its findings do not bind other persons^S3. The order sets disgorgement of about US$119.6 million and prejudgment interest of about US$25 million^S3. The Justice Department release describes the same controls failures across Mexico, India, Brazil and China^S4. Walmart's own release confirms the settlement^S5. The claim describes what the SEC said and the record supports it.

Current procedural position

SEC cease-and-desist order entered on consent on 20 June 2019, Administrative Proceeding File No. 3-19207^S3. Final.

Evidence score: 94 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.

Timeline

1. 20 June 2019SEC announces charges and consent order^S2S3

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

Revision history

• 25 October 2026 Assessment first published with label Supported.

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Sources

1. S2Tier A Walmart Charged With FCPA ViolationsUS Securities and Exchange Commission. Regulator press release. 20 June 2019.Supports the charges, the four countries and the amounts. It makes no separate bribery finding for Mexico.
2. 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
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.
4. 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.

Other claims about Walmart Inc.

• 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
• 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