In its recent 3Q FY2017 earnings call presentation Wal-Mart disclosed $29 million in Foreign Corrupt Practices Act and compliance related expenses ($24 million for ongoing investigations and inquiries and $5 million for global compliance program and organizational enhancements). The Q3 expenses of $29 million are slightly higher than the Q2 expenses of $28 million.
Doing the math, Wal-Mart’s 3Q FCPA and compliance-related costs is approximately $465,000 per working day.
Over the past approximate 4.5 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.