Walmart De Mexico Case Study

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September 2005, a former executive of Wal-Mart de Mexico who is Sergio Cicero (resigned in 2004), had email the general counsel of Wal-Mart International an information of bribes that has being paid for permits to hasten the company’s expansion in Mexico, largely through intermediaries. Based on the New York Times, Wal-Mart de México’s board chairman, chief auditor, general counsel and top real estate executive are those who Cicero implicated. Cicero also stated that, when the Wal-Mart de Mexico’s executive in 2002 is Eduardo Castro-Wright an increasing of bribery activity has occurred. Mexican gestores (fixers, some of whom operate legitimately) and who has approved payments to them has being recruited by Cicero. With a number of Wal-Mart’s senior executive that including the company’s general counsel, executive vice president and corporate secretary, top internal auditor, Latin America chief executive, and the chief administrative officer of Wal-Mart International, the Wal-Mart International general had counsel shared Cicero’s allegations. The CEO of Wal-Mart was also reported given a…show more content…
One of the most channels for illegal payments is through the agent. A company is liable for the activities of its agents, adviser, consultants and joint venture partners (“Agents”). So it is important that a policy on appointment, audit, selection and monitoring of Agents as part of an effective compliance program. Even if the Mexican payments through intermediaries do not meet the elements of an FCPA anti-bribery violation, the enforcement agencies are likely to assert that such payments violate the FCPA books and records and internal control provisions. For instance, The Times article suggests that the Mexican payments were routed through Mexican gestores who were told to submit invoices full of secret code
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