Wal-Mart in Mexico: Bribe or Operating Procedure?

As far as the U.S. government is concerned, "you benefit with U.S. laws, you have to comply with U.S. laws," and following what might be standard operating procedures by making alleged payments to expedite a business foothold won't cut it, he said.

"These allegations were not about this is the only way you can do business," he said. "This is how you can do business faster. This is about a massive coverup."

That could mean jail time for some U.S. Wal-Mart officials if they were found to have swept the alleged Mexican matter under the rug.

"Anybody who had their fingerprints on this conduct in Mexico has potential vulnerability, civilly and criminally," Frenkel said.

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