“In numerous instances, senior Walmart employees knew of failures of its anti-corruption-related internal controls involving foreign subsidiaries, and yet Walmart failed for years to implement sufficient controls comporting with U.S. criminal laws,” he added.
Furthermore, Benczkowski emphasized that the DOJ will continue its aggressive investigation and prosecution of foreign corruption.
On the other hand, FBI Assistant Director Robert Johnson commented that the bureau “will hold corporations responsible when they turn a blind eye to corruption.” He added, “If there is evidence of violations of FCPA, we will investigate. No corporation, no matter how large, is above the law.”
In a separate settlement agreement with the Securities and Exchange Commission (SEC), Walmart agreed to disgorge $144 million in profits.
