The unremarkable portion of the NY Times articles is that a foreign subsidiary of a major multi-national company operating in an FCPA high-risk jurisdiction allegedly made payments to "foreign officials" to facilitate or grease the issuance of certain licenses or permits. Even according to the NY Times, Wal-Mart's subsidiary in Mexico "had taken steps to conceal [the payments] from Wal-Mart's headquarters in Bentonville, Ark." and Wal-Mart Mexico's chief auditor altered reports sent to Bentonville discussing various problematic payments. A November 2012 NY Times article ( here ) by David Barstow (the same author as the April 2012 and December 2012 articles) rightly noted that Wal-Mart's investigation "was uncovering the kinds of problems and oversights that plague many global corporations."