In its recent 4Q FY2017 earnings call presentation Wal-Mart disclosed $17 million in Foreign Corrupt Practices Act and compliance related expenses ($12 million for ongoing investigations and inquiries and $5 million for global compliance program and organizational enhancements). The Q4 expenses of $17 million compare to Q3 expenses of $29 million, Q2 expenses of $28 million and Q1 expenses of $25 million.
Doing the math, Wal-Mart’s 4Q FCPA and compliance-related costs is approximately $275,000 per working day.
Over the past approximate 5 years, I have tracked Wal-Mart’s quarterly disclosed pre-enforcement action professional fees and expenses.
While some pundits have ridiculed me for doing so, it quickly caught on as the popular thing to do.