[F]rom 2000 until 2011, certain Walmart personnel responsible for implementing and maintaining the company's internal accounting controls related to anti-corruption were aware of certain failures involving these controls, including relating to potentially improper payments to government officials in certain Walmart foreign subsidiaries, but nevertheless failed to implement sufficient controls that, among other things, would have ensured: (a) that sufficient anti-corruption-related due diligence was conducted on all third-party intermediaries (TPIs) who interacted with foreign officials; (b) that sufficient anti-corruption-related internal accounting controls concerning payments to TPIs existed; (c) that proof was required that TPIs had performed services before Walmart paid them; (d) that TPIs had written contracts that included anti-corruption clauses; (e) that donations ostensibly made to foreign government agencies were not converted to personal use by foreign officials; and (f) that policies covering gifts, travel and entertainment sufficiently addressed giving things of value to foreign officials and were implemented. Even though senior Walmart personnel responsible for implementing and maintaining the company's internal accounting controls related to anti-corruption knew of these issues, Walmart did not begin to change its internal accounting controls related to anti-corruption to comply with U.S. criminal laws until 2011.

. . .

The internal controls failures allowed Walmart foreign subsidiaries in Mexico, India, Brazil and China to hire TPIs without establishing sufficient controls to prevent those TPIs from making improper payments to government officials in order to obtain store permits and licenses. In a number of instances, insufficiencies in Walmart's anti-corruption-related internal accounting controls in these foreign subsidiaries were reported to senior Walmart employees and executives. The internal control failures allowed the foreign subsidiaries in Mexico, India, Brazil and China to open stores faster than they would have with sufficient internal accounting controls related to anti-corruption. Consequently, Walmart earned additional profits through these subsidiaries by opening some of its stores faster. 

. . .

In Mexico, a former attorney for Walmart's local subsidiary reported to Walmart in 2005 that he had overseen a scheme for several years prior in which TPIs made improper payments to government officials to obtain permits and licenses for the subsidiary and that several executives at the subsidiary knew of and approved of the scheme. Most of the TPI invoices included a code specifying why the subsidiary had made the improper payment, including: (1) avoiding a requirement; (2) influence, control or knowledge of privileged information known by the government official; and (3) payments to eliminate fines.

. . .

In India, because of Walmart's failure to implement sufficient internal accounting controls related to anti-corruption, from 2009 until 2011, Walmart's operations there were able to retain TPIs that made improper payments to government officials in order to obtain store operating permits and licenses. These improper payments were then falsely recorded in Walmart's joint venture's books and records with vague descriptions like "misc fees," "miscellaneous," "professional fees," "incidental" and "government fee."

In Brazil, as a result of Walmart's failure to implement sufficient internal accounting controls related to anti-corruption at its subsidiary, Walmart Brazil, an entity majority-owned by WMT Brasilia, despite repeated findings in internal audit reports that such controls were lacking, Walmart Brazil continued to retain and renew contracts with TPIs without conducting the required due diligence. Improper payments were in fact paid by some of these TPIs, including a construction company that made improper payments to government officials in connection with the construction of two Walmart Brazil stores in 2009 without the knowledge of Walmart Brazil. Walmart Brazil indirectly hired a TPI whose ability to obtain licenses and permits quickly earned her the nickname "sorceress" or "genie" within Walmart Brazil. Walmart Brazil employees, including a Walmart Brazil executive, knew they could not hire the intermediary directly because of several red flags. In 2009, the TPI made improper payments to government inspectors in connection with the construction of a Walmart Brazil store without the knowledge of Walmart Brazil. WMT Brasilia was a wholly-owned subsidiary of Walmart and was a majority-owner of Walmart Brazil.

In China, Walmart's local subsidiary's internal audit team flagged numerous weaknesses in internal accounting controls related to anti-corruption at the subsidiary between 2003 and 2011, sometimes repeatedly, but many of these weaknesses were not addressed. In fact, from 2007 until early 2010, Walmart and the subsidiary failed to address nearly all of the anti-corruption-related internal controls audit findings. . . .

[O]n June 19, 2019, the traders from China, Singapore, and Malaysia attempted to manipulate the market for MDDT stock by entering matched orders to buy and sell MMDT at substantially the same times, sizes, and prices.  The SEC alleges that trades involving these five seemingly unrelated individuals from three different countries accounted for 70% of the volume in MDDT over the period in which they traded.  As described in the Complaint, IP records show that at least three of the defendants' brokerage accounts were likely accessed by the same user or users while trading MDDT. 

SALVADOR IBARRA ESCALANTE, age 43, of Mexico, also known as "Billy Escalante"

RUTH NAVA-ABARCA, age 29, of  Mexico

FLORENTINO VALENCIA-TEPOZ, age 47 of Mexico

GREGORIO VAZQUEZ-CASTILLO, age 43, of Mexico, also known as "Jaime Castillo"

JUAN DE LA CRUZ-GONZALEZ, age 32, of Mexico

SAMUEL CRUZ, age 42, of Durham, North Carolina

MIGUEL GUTIERREZ, age 24, of Henderson, North Carolina

JAIME LABRA-TOVAR, age 23, of Henderson, North Carolina

OSCAR UGALDE-ESCALANTE, age 31, of Mexico

HASAN OZVATAN, age 40, of Turkey

EMILIO GOMEZ-GONZALEZ, age 36, of Mexico

JUAN MALDONADO-HERNANDEZ, age 28, of Mexico

GEORGE LUIS MORALES, age 21, of New York, New York

TORIBIO ESCALANTE-CAMPOS, age 59, of Mexico

ERIC EVO, age 24, of Richmond, Virginia

RYAN MERCADO-RODRIGUEZ, age 24, of Henderson, North Carolina

JUAN LOPEZ-POSADA, age 40, of El Salvador

RENE ESPINOZA-TORRES, age 45, of Mexico

KELVIN FE ARELLANO-VALENCIA, age 19, of Raleigh, North Carolina

DEMETRIO VALENCIA-FLORES, age 42, of Mexico

ALVARO MENDEZ-FLORES, age 38, of Mexico.

Moreover, GOMEZ-GONZALEZ was charged with failure to register with immigration officials. In addition, NAVA-ABARCA, VALENCIA-TEPOZ, ESCALANTE-CAMPOS, IBARRA-ESCALANTE, and VAZQUEZ-CASTILLO were charged with alien harboring. Furthermore, IBARRA-ESCALANTE, VALENCIA-TEPOZ, NAVA-ABARCA, and VAZQUEZ-CASTILLO were charged with immigration-related entrepreneurship fraud.

[U]sed cooking oil, historically viewed as a waste product, has become a valuable recycled commodity over the past decade. The majority of the recycled cooking oil sold is used for biofuel, fluctuating with market demand. It can also be used as a nutritional additive to animal feed and pet food, or in the production of many consumer and industrial products.

Legitimate businesses, known renderers, collect used cooking oil from restaurants in exchange of compensation and sell it to refineries so that it can be processed and recycled.  The rendering industry estimates that there is an annual loss of approximately $45-75 million dollars from the theft of used cooking oil.

According to court records, the objective of the conspiracy was to profit from the illicit trade in large quantities of used cooking oil stolen in North Carolina, Virginia, and Tennessee, and transported to New Jersey for sale and distribution.

In particular, the Superseding Indictment alleges that members of the conspiracy repeatedly traveled to restaurants in North Carolina, Virginia, and Tennessee, in box trucks equipped with containers designed to store and transport liquids, pumps, hoses, and burglary tools, for the purpose of stealing large quantities of used cooking oil.

Additionally, members of the conspiracy transported the stolen used cooking oil in the box trucks to a warehouse in Durham, North Carolina, for consolidation and storage. Thereafter, a tanker trailer was used to transport the consolidated stolen used cooking oil to Virginia and elsewhere. . . .