Emergence of fraud On 21 September, 2005, Ms.

Munich who was part of the general counsel of Wal-Mart got wind of corruption in Wal-Mart De Mexico when she received an email from the former executive mentioned previously, Sergio Cicero Zapata. Mr. Cicero indicated corruption taking place in Mexico with authorization from top level management and requested a meet. Ms. Munich who was no stranger to the level of corruption in Mexico, responded quickly to the request for the meeting by getting the board to assent to the adoption of a stringent anticorruption policy which in essence forbade the employees to bribe the authorities and Mr.Torres-Landa,a lawyer, was arranged for debriefing of Mr. Cicero, Ms. Munich flying in from Bentonville for the third briefing herself. Mr. Ciceros account given to Mr. Torres-Landa of how the bribes were carried out and then hidden with fraudulent accounting raised fingers on a lot of top executives of Wal-Mart De Mexico, not sparing its top real estate executive, its general counsel and its chief auditor, laying the maximum responsibility on Eduardo Castro-Wright, The Chief Operating Officer in Mexico. In telling about the bribery scam, Mr. Cicero also implicated himself, explaining his contribution in the whole scenario. One of his jobs was to recruit the gestores, individuals who hand the actual bribes over, some of whom are even considered to be legitimate. His work was to involve them in devising strategies on which officials to bribe and authorize the gestores payments covering their fees and the bribes. Invoices by gestores were filled with ambiguous descriptions of services rendered where the whole system was managed through codes on the invoices that had meaning for only a few executives. The executives Mr. Cicero implicated while being questioned by Mr. Torres-Landa, allegedly received regular schedules containing details of payments made, after which the bribes were shown in the accounts as legal fees. Special care was taken to keep the head office in dark. To ascertain the credibility of Mr. Ciceros allegations, his motives of sharing the information were explored. It turned out that he resigned in September 2004, from Wal-Mart de Mexico after being passed on for general counsel of Wal-Mart de Mexico in early 2004 which made him feel really underappreciated after haggling with the greedy officials who demanded bribes and bearing the weight of corruption on his conscience for years. He also did not seem to be interested in selling the information he had. His allegations on MR. Eduardo Castro-Wright also carried weight because this was not the first time Mr. Castro-Wright was being accused of corruption. A private investigation in 2003 by Kroll Inc., revealed that the increase in Wal-Mart de Mexicos sales increased by helping bulk consumers get around sales taxes.