All Wal-Mart, all the time.
04:00: Will this fundamentally change FCPA compliance going forward?
06:06: How will Mexico respond? How will the DOJ?
07:11: Impacting the News Corp. story
08:22: Will this kill the FCPA reform movement?
Vis-a-vis: (1) Compliance defense (2) respondeat superior (3) defining “foreign official”
12:45: Were the people receiving the payments foreign officials?
13:10: My take on the effect on reform efforts, and how the Chamber could turn this to their advantage
25:30: Were these facilitation payments?
30:30: Legal under local law exemption? And how does the local law element interact with the facilitation payments element? And what does Mexican law say?
34:18: Books-and-records issues. A “legal facilitation payments” account? Good idea?
37:35: Self-disclosure. What happened?
44:12: What happened with the internal investigation?
50:25: What did Wal-Mart do right?
Listen here:[audio https://thisweekinfcpaaudio.files.wordpress.com/2012/04/episode-35.mp3]
Download here: Episode #35