Wal-Mart is the world’s largest retailer, and recently, it was in one of the world’s largest boiling pots of Foreign Corrupt Practices Act (FCPA) stew as well. Now, the company has released its first-ever Global Compliance Report, detailing the internal controls it has put into place to avoid this type of scandal moving forward.

The report, which details the efforts taken under the umbrella of the company’s chief compliance officer, focuses on three critical areas: people, policies and processes, and systems. Overall, the report says, the company has spent more than $100 million improving its internal controls since the first bribery allegations were released.

A large portion of those funds went towards hiring in the risk and compliance department, and Wal-Mart says that more than 2,000 associates were working within the department by the end of the 2014 fiscal year. In addition, the company has reorganized its compliance structure, hiring a global chief compliance officer, a global anti-corruption officer, and 10 chief compliance officers with the intent of boosting internal controls.

Bloomberg reports that the company’s audit committee within its board of directors has also been instrumental in introducing change, having met 22 times over the past year, according to a proxy statement. 13 of those meetings focused exclusively on compliance matters and the ongoing corruption investigation.

Since Wal-Mart was originally accused of bribery within its Mexican subsidiary in April 2012, the company has spent more than $400 million in legal fees and compliance costs. According to company figures released in February, Wal-Mart expects to spend an additional $200 million and $240 million in legal fees and compliance costs as well.

An April 2012 New York Times article originally uncovered an attempted bribery cover-up within the company. A former Wal-Mart de Mexico executive claimed the company engaged in rampant FCPA violations in an effort to win market dominance, but the company did not notify American or Mexican officials and did not reprimand any of the executives involved.


For more on the FCPA in legal news, check out these recent IC articles:

GE acquisition of Alstom’s energy operations complicated by DOJ investigation

GlaxoSmithKline investigating bribery of foreign doctors

Navigating the minefield: Special risks in FCPA cross-border internal investigations