Walmart Says Global Ethics and Compliance Chief Jay Jorgensen Is Leaving

Daniel Trujillo

Walmart Inc. announced today that Jay Jorgensen, its executive vice president and global chief ethics and compliance officer, is leaving the company to pursue other opportunities. He will be replaced by Daniel Trujillo, the company’s senior vice president and international chief compliance officer, on Feb. 1.

In a memo to Walmart associates Friday morning, Chief Legal Officer Rachel Brand announced the changes, saying, “Under Jay’s leadership we designed Walmart’s program to manage compliance risks associated with 14 diverse subject areas ranging from anti-corruption to food safety. . .We also established a chief ethics and compliance officer and centralized compliance team in every international market.”

Both men joined Bentonville, Arkansas-based Walmart in October 2012 with marching orders to build a world-class compliance program, shortly after the U.S. Department of Justice and the U.S. Securities and Exchange Commission opened investigations into allegations that Walmart personnel systematically bribed Mexican officials so it could more quickly open stores in that country, in violation of the Foreign Corrupt Practices Act.

The world's largest retailer has previously reported that it spent over $500 million on its beefed up global compliance program and related enhancements, including some 2,000 compliance personnel. It spent $3 million on compliance and related functions in this year’s third quarter alone, according to its most recent filing to the SEC in November.

Brand’s memo said Jorgensen and Trujillo “have worked closely together at every step” of the program, and that their shared experience “will provide continuity and a smooth transition.”

Jorgensen was a partner at Sidley Austin before he joined Walmart. He also had served as a law clerk to U.S. Supreme Court Chief Justice William Rehnquist.

Before Trujillo was hired at Walmart, he was deputy general counsel and director of compliance at Houston oil services company Schlumberger Ltd., where he worked for 15 years.

“I’ve had the pleasure of getting to know Daniel over the past nine months,” Brand’s memo said, “and have seen first-hand his ability to lead strategic change and strengthen our business. His integrity, high expectations and passion for the business and our associates will ensure our continued success in leading a strong ethics and compliance program.”

The announcement came as Walmart prepares to settle its lingering, seven-year FCPA investigation with the SEC and DOJ. In November 2017 the company announced that it had set aside $283 million to settle the case with the federal government.

But negotiations appeared to deadlock at times this year as the two sides worked out the details of the deal. The final settlement is expected early next year.