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

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.

The FCPA’s Impact On Raising Capital

The 2014 article “FCPA Ripples” goes in-depth, using various case studies, to demonstrate how settlement amounts in an actual Foreign Corrupt Practices Act enforcement action are often only a relatively minor component of the overall financial consequences that can result from FCPA scrutiny or enforcement. Numerous prior posts have done so as well (see here).

In addition to pre and post-enforcement action professional fees and expenses, market capitalization, credit ratings, M&A activity, lost or delayed business opportunities, and offensive use of the FCPA (to name just a few ripples) this post highlights how FCPA scrutiny and enforcement can also negatively impact a company’s ability to raise capital.

Friday Roundup

Elevate, further to the clustering phenomenon, transparency, dismissed, and incomplete. It’s all here in the Friday roundup.

Elevate

Learning a new topic or elevating your knowledge and practical skills in a topic is not just for formal students in formal educational settings. Professionals in the workplace can also benefit from back to “school” experiences.

For professionals in the FCPA space – or wishing to join the FCPA space – the FCPA Institute serves this objective and has “graduated” approximately 200 hundred diverse professionals since its launch in 2014.

The next FCPA Institute will take place in Nashville on May 3-4th. See here to learn more and to register.

Friday Roundup

Scrutiny alerts, post-enforcement action compliance enhancements, my own two cents, reality TV, and for the reading stack. It’s all here in the Friday roundup.

Scrutiny Alerts

OSI Systems

This December 2017 post highlighted the unusual origin of OSI Systems FCPA scrutiny – a short seller published a research report accusing the company of corruption. Yesterday, OSI Systems formally disclosed:

Friday Roundup

Scrutiny alerts and updates, ripple, didn’t fit the narrative, too far into the weeds, the emerging global facade of enforcement and for the reading stack. It’s all here in the Friday roundup.

Scrutiny Alerts and Updates

Amway

Multilevel marketing companies Avon and Nu Skin Enterprises previously resolved FCPA enforcement actions concerning conduct in China. (See here, here, here, here and here for prior posts). Multilevel marketing companies USANA and Herbalife are currently under FCPA scrutiny for its business practices in China.