Read more about the impact and continuing evolution of the FCPA in June's feature story.
When potential FCPA violations rear their head, a thorough investigation into what went wrong and why is crucial. But when you are criss-crossing borders and double-checking every party along a supply chain, the cost of an investigation can easily balloon out of control. Take Wal-Mart, which says it voluntarily disclosed internal investigative activity to the government in November 2011 (well before the New York Times first reported bribery allegations). In its March 26 10-K, Wal-Mart reported that it had spent $157 million in the last fiscal year on FCPA investigations, a figure that includes defending related shareholder lawsuits.