Walmart Inc.

In April 2012 the Associated Press relayed a New York Times report that Wal-Mart investigators had found hundreds of suspect payments in Mexico and that the company ended its internal probe^S1. On 20 June 2019 the SEC charged Walmart with books and records and internal controls violations covering subsidiaries in Brazil, China, India and Mexico^S2. The SEC order describes the 2005 Mexico allegations and the handling of the inquiry but makes no finding that Mexican officials were bribed^S3. Walmart entered a non-prosecution agreement and WMT Brasilia pleaded guilty^S4. Walmart put the combined payment at US$282.7 million^S5.

Also known as: Wal-Mart Stores, Inc., Walmart
Headquarters: United States
Records from: United States
Current status: Operating retailer based in Bentonville, Arkansas. Its US foreign bribery matters were resolved on 20 June 2019 through an SEC cease-and-desist order^S3, a three-year non-prosecution agreement with the Justice Department and a guilty plea by its Brazilian subsidiary WMT Brasilia^S4^S5.

Scope. This record covers the US FCPA resolution of 2019 and the 2012 reporting on Mexico. It does not cover Walmart de Mexico as a separately listed company, Mexican domestic proceedings, US shareholder suits or Walmart's opioid litigation.

Claims assessed

3 claims. Scores grade the evidence for each claim, not the organization.

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

Cases and proceedings

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
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.
- 20 June 2019 NPA with Walmart and guilty plea by WMT Brasilia, combined criminal penalty of US$137 million^S4

Responses on record

Walmart Inc., 21 April 2012, on An Associated Press report of 21 April 2012, relaying a New York Times investigation, said...
A Walmart spokesman said the company was deeply concerned and was working to determine what happened, and said many of the alleged activities occurred more than six years earlier.^S1
Walmart Inc., 20 June 2019, on Walmart said on 20 June 2019 that its global resolution with the Justice Department and th...
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

25 October 2026 Profile and 3 assessments first published. Records checked to 25 October 2026.

Source records

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.
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
S1Tier C Wal-Mart covered up bribe campaign in Mexico, report saysAssociated Press (via Fox News). Press report. 21 April 2012.AP summary, with no named reporter, of the New York Times investigation and Walmart's response. The Times article was titled Vast Mexico Bribery Case Hushed Up by Wal-Mart After Top-Level Struggle and dated 21 April 2012, as cited in (S6). It reports allegations and is not a finding.Link working, checked 25 October 2026
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.
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.
S6Tier A Letter to Michael T. Duke, Chief Executive Officer, Wal-Mart Stores, Inc.US House of Representatives, Ranking Members of the Committee on Energy and Commerce and the Committee on Oversight and Government Reform. Commission report. 23 April 2012.Congressional letter that cites the Times article by title and date and restates its US$24 million figure. It records what the Times reported and is not a finding.Link working, checked 25 October 2026