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In this special bonus podcast, I am joined by Jay Rosen to discuss the stunning resolution to one of the longest running bribery, corruption and money-laundering sagas on the international stage, the FCPA enforcement action against the world’s largest retailer--Walmart. Some of the highlights include: · The background facts;· How significant is the case;· Is the penalty too low (or too high)?· Response of Walmart;· Lessons learned for the compliance professional;· Was there self-disclosure and full cooperation?· How should we analyze the monitor requirement under the Benczkowski Memo? Resources: The documents for this matter include:From the Department Of Justice1. Criminal Information2. Non-Prosecution Agreement3. Plea Agreement and Statement of Facts4. Press Release From the SEC, Cease and Desist Order and Press Release. See also Tom’s Blog Post Walmart Enforcement Action-Part 1: Introduction. Tom will have multiple blog posts on the Walmart enforcement action so keep abreast on the FCPA Compliance Report.
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In this special bonus podcast, I am joined by Jay Rosen to discuss the stunning resolution to one of the longest running bribery, corruption and money-laundering sagas on the international stage, the FCPA enforcement action against the world’s largest retailer--Walmart. Some of the highlights include: · The background facts;· How significant is the case;· Is the penalty too low (or too high)?· Response of Walmart;· Lessons learned for the compliance professional;· Was there self-disclosure and full cooperation?· How should we analyze the monitor requirement under the Benczkowski Memo? Resources: The documents for this matter include:From the Department Of Justice1. Criminal Information2. Non-Prosecution Agreement3. Plea Agreement and Statement of Facts4. Press Release From the SEC, Cease and Desist Order and Press Release. See also Tom’s Blog Post Walmart Enforcement Action-Part 1: Introduction. Tom will have multiple blog posts on the Walmart enforcement action so keep abreast on the FCPA Compliance Report.
Learn more about your ad choices. Visit megaphone.fm/adchoices