In 2019, Walmart was charged with violating the Foreign Corrupt Practices Act for "failing to operate a sufficient anti-corruption compliance program for more than a decade," adding that the corporation allowed violations to occur "even in the face of red flags and corruption allegations." Some of those "red flags" included Walmart employees writing letters and emails to Walmart executives expressing their concerns. One employee had received "a wink and a nod" from another employee when inquiring about whether a real estate transaction would violate the FCPA. Another employee noted that Walmart employees in India were making "improper payments to government officials." The DOJ asserted that Walmart executives were aware of these complaints but did not conduct an inquiry at that time.