The publicity and costs to Wal-Mart have been well documented. On his FCPA Professor website, Professor Koehler has consistently stated that he views this scandal as largely a failure of corporate governance. In a post entitled, “Wal-Mart One Year Later” he said, “corporate governance, or lack thereof, is what made the NY Times April 2012 remarkable. This is the reason why Wal-Mart generated all the buzz it did a year ago this week and I’ve consistently held the view that the Wal-Mart story is a corporate governance sandwich with the FCPA as a mere condiment.” I thought about Professor Koehler’s observations on this failure in light of Clifford’s article and wondered what the Board’s legal obligations might be.
via What Is A Board’s Responsibility For Compliance? — FCPA Professor
