Second, according to the Times, Wal-Mart's investigation "was uncovering the kinds of problems and oversights that plague many global corporations." Third, according to the Times, Wal-Mart's internal reviews began in Spring 2011 – long before the Times April 2012 article, when Wal-Mart's general counsel learned of an FCPA enforcement action against Tyson Foods (like Wal-Mart, a company headquartered in Arkansas). Finally, the recent guest post on the FCPA Blog states that Wal-Mart's pre-enforcement action professional fees and expenses can "be looked at like accumulated liability for a toxic waste site: First a determination of the origin, size and places of the contamination, then the costs of the clean up and damages." Accepting the analogy, perhaps you've heard that Superfund and other environmental clean-up costs frequently turn into boondoggles as well. (See e.g., here ).