"Other changes the company has made - including mandating that any potential foreign corruption violations be reported to corporate headquarters and the board - may make it more difficult for senior executives to plead ignorance in the future. "It is in Walmart's interest, particularly as it negotiates with federal prosecutors, to show how it has strengthened its compliance efforts." However, the new Times story makes the point that while Walmart has reported spending more than $400 million on its internal investigations, compliance programs and related legal costs (though, to be fair, the US Department of Justice has never officially confirmed or denied a probe into the Walmart bribery allegations), there are those who suggest that its compliance moves have been perfunctory or "window dressing." Fascinating story, and you can read the entire piece here (though you may be a Times subscriber to do so).