FCPA Investigative Costs Archives

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

By Mike Koehler on August 17, 2018 in FCPA Investigative Costs, Investigative Fees, 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.

The Many Issues To Consider From The Dun & Bradstreet Enforcement Action

By Mike Koehler on April 25, 2018 in Dun & Bradstreet, FCPA Investigative Costs, Gray Cloud, Internal Controls, Investigative Fees, Kokesh, Statute of Limitations, Voluntary Disclosure

Some people simply read FCPA enforcement actions, accept the enforcement theories advanced, record the enforcement statistics, and go about their day.

Not here at FCPA Professor. Just because the FCPA is a fundamentally sound statute, does not mean that FCPA enforcement is necessarily fundamentally sound.

Prior posts here and here went in-depth into the SEC’s $9.2 million Foreign Corrupt Practices Act enforcement action against Dun & Bradstreet based on the conduct of two indirect Chinese subsidiaries from 6 – 12 years ago.

This post continues the analysis by highlighting the many troubling or notable issues to consider from the enforcement action.

Roundup Of Scrutiny Alerts And Updates

By Mike Koehler on March 2, 2018 in Albemarle Corp., Applied Energetics, Cognizant Technology Solutions, Exterran Corp, FCPA Investigative Costs, Fresenius Medical Care, Investigative Fees, Merger Issues, Monitor, Orthofix International, Stericycle, World Fuel Services

Add some to the list, take a few off, future settlement, continuing to seemingly “boil the ocean,” and monitor costs.

This time of year is heavy on annual reports and other corporate disclosures and this post rounds up various scrutiny alerts and updates.

Albemarle Corp.

The North Carolina based chemical company recently disclosed:

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

By Mike Koehler on February 21, 2018 in FCPA Investigative Costs, Wal-Mart

In yesterday’s 4Q FY2018 earnings call presentation WalMart disclosed $7 million in Foreign Corrupt Practices Act and compliance related expenses ($4 million for ongoing investigations and inquiries and $3 million for global compliance program and organizational enhancements).

The Q4 expenses of $7 million compare to the following recent quarterly expenses: Q3 FY2018 $5 million, Q2 FY2018 $12 million, Q1 FY2018 $16 million; Q4 FY2017 $17 million; Q3 FY2017 $29 million; Q2 FY 2017 $28 million, and Q1 FY2017 $25 million).

Doing the math, Wal-Mart’s 4Q FY2018 FCPA and compliance-related costs is approximately $113,000 per working day.

Friday Roundup

By Mike Koehler on February 9, 2018 in DOJ, FCPA Investigative Costs, FCPA Statistics, GlaxcoSmithKline, Investigative Fees, Juniper Networks, Keppel Offshore & Marine, Misonix, Related Civil Litigation, Richard Bistrong, Uncategorized, USANA Health Sciences, Year in Review 2017

DOJ’s year in review, ripple, scrutiny alerts and updates, simply false, and amusing. It’s all here in the Friday roundup.

DOJ’s Year In Review

The DOJ Fraud Section recently released its year in review. According to the document, “the FCPA Unit has 32 prosecutors.” When reviewing the statistics in the document keep in mind that the FCPA Unit “investigates and prosecutes cases under the FCPA and related statutes.” In other words, the statistics include non-FCPA matters such as when the DOJ charges or prosecutes alleged “foreign officials” for money laundering and related offenses.

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

The Many Issues To Consider From The Dun & Bradstreet Enforcement Action

Roundup Of Scrutiny Alerts And Updates

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

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