Daniel Trujillo to Lead Wal-Mart International Compliance Efforts
Wal-Mart Stores Inc. has named Daniel Trujillo, currently deputy general counsel and director of compliance at Schlumberger Limited in Houston, to lead its international compliance efforts. The company announced his appointment in an internal memo [PDF] Tuesday.
Trujillo, whose formal title will be senior vice president and chief compliance officer for Walmart International, begins his new job at corporate headquarters in Bentonville, Arkansas, on October 29. He declined comment.
The Wal-Mart memo said Trujillo will be responsible for reviewing, assessing, and integrating our compliance efforts outside of the U.S.; leveraging talent, resources, and compliance best practices across our international markets; and ensuring appropriate training, monitoring, education, and audit of our international compliance functions.
It was jointly issued by general counsel Jeff Gearhart and Walmart International CEO Doug McMillon.
Ryan McConnell, a partner at Baker McKenzie in Houston, has worked with Trujillo and described him as a cutting-edge kind of compliance officer, who uses technology and risk-based analysis to target problem areas in a company.
McConnell and Trujillo co-authored an article for CorpCounsel.com in May, entitled Playing Moneyball in the Compliance Department. They discussed using technology, empirical data, and statistics to effectively manage allegation programs, document production, due diligence, compliance audits, and training.
This approach is especially useful to companies that are working to comply with the Foreign Corrupt Practices Act, which prohibits bribing foreign officials to advance business interests.
Trujillos appointment comes as Wal-Mart works to clean up its foreign operations and to settle U.S. and Mexican investigations into possible FCPA violations.
The worlds largest retailer, Wal-Mart disclosed its own internal investigation as well as the federal probe in late 2011, after The New York Times began reporting on alleged bribes paid by its Mexico subsidiary to expand business in that country.
In its latest quarterly filing with the Securities and Exchange Commission on September 9, Wal-Mart said it spent $51 million in the first six months of 2012 on the internal investigation. It said Jones Day is conducting the probe.
David Tovar, head of the companys corporate communications, said Trujillos appointment is part of an ongoing process.
"Wal-Mart is committed to having strong and effective compliance programs around the world, Tovar said. Over the past 18 months, we have made improvements to our global compliance programs and have taken a number of specific, concrete actions with respect to our processes, procedures, and people.
Previously, the company announced in April it was naming Tom Geana former U.S. attorney for the Western District of Arkansas from 2001 to 2004as its global FCPA compliance officer. Gean, who spent eight years as Wal-Marts chief compliance officer, will report to Trujillo.
At the French-based Schlumberger, Trujillo worked in more than 50 countries in numerous legal roles in Latin America, Europe, Africa, the Middle East, and the United States. Schlumberger bills itself as the world's largest supplier of technology and services to the oil and gas industry.
Prior to joining Schlumberger Trujillo worked for Cargill Incorporated and Impregilo SpA. He has nearly 21 years of experience in setting up and managing legal and compliance departments and programs, and speaks five languages.