Walmart is committed to complying with anti-money laundering laws applicable to its global businesses. We maintain a risk-based anti-money laundering (“AML”) program that is reasonably designed to prevent the company from being used to facilitate money laundering.
Walmart’s AML policy sets requirements for the key elements of the program including:
- Standards & Procedures – Each market maintains a set of procedures that provide details on how the company meets local regulatory requirements. Standards and procedures are in place concerning:
Reporting of large cash and suspicious activities;
Data collection and customer verification;
Scanning for sanctioned parties;
Responding to law enforcement.
- Training & Communication – Associates, who perform relevant functions, are trained on ways to mitigate AML risk. Enhanced training is provided to higher risk stores, clubs and processes to further improve the execution of AML actions. Periodic training on trends, best practices, and regulatory changes is provided to associates that work within the AML compliance functions. Methods of communication and training vary by market but often include online learning courses and in-person facilitated training sessions.
- Monitoring – Risk-based daily monitoring of operational execution is performed by managers or process owners that have responsibility for compliance within their function.
- Audits – As the sale of financial services is a regulated activity, it is common across markets for regulations to require formal reviews of our AML program by an independent third party. Formal responses to recommendations and violations identified in audits are created and reported to executive leadership.
- Reporting Suspected Illegal Activity – In most markets where we operate, when the AML team suspects illegal activity has occurred, it has a responsibility to report this data to law enforcement for investigation. The company is committed to cooperating with government and law enforcement authorities in the investigation and enforcement of AML laws and regulations in connection with transactions involving the Company, its customers, partners and vendors.