The Foreign Corrupt Practices Act Revisited: The Case of Walmart of Mexico

This case examines the allegations and subsequent investigation made by the U.S. Department of Justice into Walmart’s Mexican subsidiary concerning bribery of government officials. The primary subject matter of the case is the Foreign Corrupt Practices Act (FCPA) and its enforcement. A secondary issue examined in this case is the management of foreign subsidiaries and corporate social responsibilities. The case reviews the important components of the FCPA, looks into the specific acts of potentially illegal behavior in Mexico and the United States relative to the incident, and proposes the question of the continued legitimacy of the Act. The paper provides a view into a potentially groundbreaking case of foreign corruption, how things went wrong, and how the situation could have been better managed.