The Wal-Mart GC Who Resigned During the Mexico Bribery Scandal

Note: This story has been updated.

When Maritza Munich first learned of alleged bribery in September 2005, the general counsel of Wal-Mart Stores Inc.’s international division acted quickly. The New York Times reported Sunday that within days of receiving the tip from former Wal-Mart executive and in-house lawyer Sergio Cicero Zapata, Munich had hired a lawyer to debrief him in Mexico City. By October, the GC flew to Mexico to meet with both men.

Cicero, a member of the subsidiary’s real estate department, claimed the company paid out $24 million in bribes to foreign officials in 2005 to expedite the issuance of licenses and permits for new stores. Munich resigned February 1, 2006. Although the reasons for her departure are not yet known, her views of how the company should investigate Cicero’s allegations were reported by the Times to be at odds with top executives of the parent company.

Munich’s attorney, Nereida Melendez-Rivera, told CorpCounsel.com that Munich is currently engaged in communications with Wal-Mart. Melendez-Rivera, a former assistant U.S. attorney, declined to comment on the specifics of the Wal-Mart case.

Prior to joining Wal-Mart, Munich held various general counsel positions within divisions of Procter & Gamble. She was familiar with corporate culture in Mexico, having lived in the country for five years while serving as P&G’s GC for Mexico and Central America.

The Times reported that in 2004 Munich encouraged Wal-Mart’s board to adopt a strict anticorruption policy. Once claims of corruption surfaced, she continued to push the company to abide by the applicable laws of both the U.S. and Mexico. The GC urged executives to use independent investigative resources and objected to Wal-Mart’s choices to limit its investigation or have it led by individuals who were targeted.

A preliminary internal review in November 2005 gave investigators what they said was “reasonable suspicion” that laws had been violated both in Mexico and the U.S., according to the Times. But while Wal-Mart executives were still weighing whether or not they should dig deeper, Munich submitted her resignation. According to a memo obtained by the Times, the GC urged executives to expand the investigation. It was one of her last acts regarding the investigation before she resigned.

When Munich left Wal-Mart, she returned to her native Puerto Rico, where she practiced corporate law at Rivera, Tulla & Ferrer. She stayed on the board of directors of the Hispanic National Bar Foundation, which is sponsored by Wal-Mart, until 2009.

Current board member Armando Castro, a DLA Piper partner, overlapped on the board with Munich. Although he says he is “not very familiar with what happened with her at Wal-Mart,” Castro remembers Munich as an active board member who successfully engaged Wal-Mart employees and executives in the foundation’s events.

In 2010, Munich took an in-house counsel position with insurer Medical Card System, Inc., in Puerto Rico, and is currently the company’s chief legal officer and general counsel.