Bribes are not legal fees. Potential bribes were also not disclosed on the books. This violation involves not only Wal-Mart de Mexico's accountants, but also the CEO, CFO and auditors who were supposed to ensure that the records are transparent, accurate and reliable. Sarbanes Oxley also requires CEOs and CFOs to certify that financial reports are accurate. The United States Department of Justice encourages companies to conduct internal investigations and disclose relevant facts to authorities. Any suspected violation of the Foreign Corrupt Practices Act must be reported to the US DOJ, which was not the case for Wal-Mart. According to the New York Times, Wal-Mart contacted the Justice Department, but after hearing about the Times’