Controlling the costs of an FCPA internal investigation

Experience, team size, language and the length of the investigation are key factors to consider

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.

Associate Editor

Melissa Maleske

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