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Issues To Consider From The Walmart Enforcement Action

By on June 24, 2019 in FCPA Investigative Costs, Gray Cloud, Investigative Fees, Kokesh, Statute of Limitations, Wal-Mart
Issues

This prior post went in-depth into the long-awaited Walmart Foreign Corrupt Practices Act enforcement action in which the company agreed to pay the DOJ/SEC approximately $283 million. This post highlights additional issues to consider from the enforcement action.

Timeline

Walmart was under FCPA scrutiny since approximately mid-2011. Thus, from start to finish its FCPA scrutiny lasted an unconscionable approximate 8 years. There is simply no excuse for this and the DOJ/SEC have long-recognized the issues associated with long-drawn out investigations.

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Checking In On Wal-Mart’s Pre-Enforcement Action Professional Fees And Compliance Enhancements Expenses

By on February 19, 2019 in FCPA Investigative Costs, Investigative Fees, Wal-Mart
Wal-Mart

In today’s 4Q earnings call presentation, Wal-Mart disclosed $6 million in Foreign Corrupt Practices Act and compliance related expenses ($3 million for ongoing investigations and inquiries and $3 million for global compliance program and organizational enhancements).

Doing the math, Wal-Mart’s 3Q FY2019 FCPA and compliance-related costs are approximately $97,000 per working day.

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The Many Issues To Consider From The Cognizant Technology Enforcement Action

By on February 19, 2019 in Cognizant Technology Solutions, DOJ FCPA Corporate Enforcement Policy, FCPA Investigative Costs, Gray Cloud, Investigative Fees, Permits / Licenses / Customs / Tax, Third Parties, Transparency
Issues

Previous posts here and here highlighted the recent Foreign Corrupt Practices Act enforcement action against Cognizant Technology Solutions and two of its former executives.

This post continues the analysis by highlighting several issues to consider.

Timeline

As highlighted in this prior post, Cognizant disclosed its FCPA scrutiny in a September 2016 SEC filing. Thus from start to finish, Cognizant’s FCPA scrutiny lasted approximately 2.5 years. While 2.5 years is shorter than recent medians of over 4 years (see here), 2.5 years is still too long for FCPA scrutiny to last.

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Wal-Mart’s Pre-Enforcement Action Professional Fees And Compliance Enhancements Top $900 Million

By on November 16, 2018 in Collateral Effects, FCPA Investigative Costs, Investigative Fees, Wal-Mart
Wal-Mart

In yesterday’s 3Q FY2019 earnings call presentation, Wal-Mart disclosed $9 million in Foreign Corrupt Practices Act and compliance related expenses ($6 million for ongoing investigations and inquiries and $3 million for global compliance program and organizational enhancements). The 3Q figures are higher than 2Q figures and 1Q figures.

Doing the math, Wal-Mart’s 3Q FY2019 FCPA and compliance-related costs are approximately $145,000 per working day.

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Checking In On Wal-Mart’s Pre-Enforcement Action Professional Fees And Compliance Enhancements

By on August 17, 2018 in FCPA Investigative Costs, Investigative Fees, Wal-Mart
Wal-Mart

In yesterday’s 2Q FY2019 earnings call presentation WalMart disclosed $8 million in Foreign Corrupt Practices Act and compliance related expenses ($5 million for ongoing investigations and inquiries and $3 million for global compliance program and organizational enhancements).

Doing the math, Wal-Mart’s 2Q FY2019 FCPA and compliance-related costs is approximately $130,000 per working day.

Over the past approximate 6 years, I have tracked Wal-Mart’s quarterly disclosed pre-enforcement action professional fees and expenses. While some pundits ridiculed me for doing so, it quickly caught on as the popular thing to do.

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