On June 20, 2019, officials announced that multinational retailer Walmart, Inc. (“Walmart”) and Brazilian subsidiary WMT Brasilia S.A.R.L. (“WMT Brasilia”) agreed to pay combined penalties of $137 million to resolve DOJ’s investigation into alleged FCPA violations in several countries.  The government’s allegations involved the companies’ anti-corruption controls in relation to due diligence on third-party intermediaries.  Parent company Walmart entered into a three-year non-prosecution agreement (“NPA”) with the government and agreed to a two-year independent corporate monitorship.  WMT Brasilia pleaded guilty to one count of causing FCPA books-and-records violations.

United States v. WMT Brasilia SarL, No. 19-cr-192 (E.D. Va.)

DOJ Press Release