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Wal-Mart’s FCPA Scrutiny DID NOT Begin With The April 2012 NY Times Article


If you follow media reporting (and certain FCPA commentators) you probably heard the narrative before: Wal-Mart’s Foreign Corrupt Practices Act began with the April 2012 New York Times article.

However, this is false.

Set forth below is the chronology of Wal-Mart’s FCPA scrutiny – as even reported by the New York Times – and based on other information in the public domain.

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About That New Yorker Trump Organization Azerbaijan Story

kidding me

For years FCPA Professor has highlighted numerous examples of – shall I say – not the media’s finest moments when it comes to Foreign Corrupt Practices Act reporting. (See here, here, here and here).

Although FCPA Professor has highlighted several examples, Adam Davidson’s recent New Yorker article about the Trump Organization in Azerbaijan (see here for the original post highlighting several concerns about the article) and his subsequent comments and writing about the matter are in a league of their own.

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