Principal Ariel Neuman and associate Naomi Solomon authored the Daily Journal article, “How Walmart Pulled off an FCPA Win,” analyzing the retailer’s recently concluded seven-year Foreign Corrupt Practices Act investigation. The article provides an in-depth look into Walmart’s mishandling of its anti-corruption efforts prior to the investigation and details the compliance strategies the company implemented post-investigation to obtain a significantly reduced fine, with no employee or executive facing prosecution or sanctions of any kind. Neuman and Solomon conclude by providing several key takeaways that can be utilized by companies and their counsel in future FCPA investigations.
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