The recent report in The New York Times of allegations that Wal-Mart suppressed an intenal inquiry into bribery in Mexico (see, for instance, Charlie Savage’s April 26, 2012 article, With Wal-Mart Claims, Greater Attention on a Law), has led to an increased national focus on the Foreign Corrupt Practices Act. A large group of former U.S. Attorneys are likely to be kept quite busy with FCPA issues. Wal-Mart named Tom Gean, shown above left, former U.S. Attorney for the Western District of Arkansas, Global Compliance Officer. Gaen has been with Wal-Mart’s legal department since 2004.
Greenberg Traurig is conducting a worldwide review of Wal-Mart’s compliance programs, reporting to Gean. The Greenberg effort is led by former U.S. Attorneys John A. Pappalardo, shown above right, and NAFUSA board member Joe D. Whitley, shown above left.
Wal-Mart has retained Jones Day to conduct its internal investigation and it is led by NAFUSA board member Karen P. Hewitt, shown right.
Yet another NAFUSA member, David N. Kelley, shown left, is one of the partners at Cahill Gordon & Reindel LLP, serving as legal counsel for the Wal-Mart Audit Committee.