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Walmart Doj Non Prosecution Agreement

Walmart stated that the payments in question were made prior to 2011 and that since then it has conducted a thorough internal investigation, collaborated with the SEC and DOJ, and has taken steps to implement its global anti-corruption investigation. Over the past seven years, the retailer has spent more than $900 million on this program, FCPA investigations and applications, and «organizational improvements.» The SEC and DOJ have recognized these measures in their resolution agreements with Walmart. Walmart entered into a three-year non-prosecution agreement (pdf) with the DOJ and agreed to maintain an independent corporate compliance monitor for two years. Walmart has also entered into a non-prosecution agreement with the Department of Justice. This means that the department will not sue the company if it fulfils the obligations stipulated in the agreement for a period of three years. Walmart entered into a three-year non-prosecution agreement and agreed to maintain an independent corporate compliance monitor for two years. The $137 million fine reflects a 20% reduction in the lower U.S. criminal guidelines for the mexican behaviour fine and a 25% reduction in the share of behaviour in Brazil, China and India. Walmart fully cooperated with the investigation in Brazil, China and India. Walmart cooperated with the investigation in Mexico, but did not provide documents and information to the government on time and did not conflict with the government`s request to interview a witness before Walmart interviewed the witness. Walmart did not voluntarily open the behavior in Mexico and did not announce its behavior in Brazil, China and India until after the government began investigating behavior in Mexico. The $137 million fine includes the recovery of US$3.6 million and a fine of $724,898 from WMT Brasilia.

On June 20, 2019, the Department of Justice and the Securities and Exchange Commission announced long-awaited resolutions with Walmart, Inc. regarding violations of books and records and internal accounting rules of the Foreign Corrupt Practices Act (FCPA). In addition to a three-year non-prosecution agreement and approval of a two-year compliance monitor, Walmart has agreed to pay US$137 million to resolve DOJ criminal complaints and an additional $144 million to settle the SEC`s parallel civil actions. WmT Brasilia, LLP («WMT») , the Brazilian subsidiary of 100% of Walmart, pleaded guilty as part of the resolution. In the criminal transaction proceedings, WMT Brasilia LLP, Walmart`s Brazilian subsidiary, pleaded guilty to failing to maintain specific records in accordance with FCPA accounting and registration rules.

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