What is the policy? 

If the Walmart Marketplace FinCEN Covered Goods policy requirements and agreements are not maintained as stated below, Walmart, in its sole discretion, has the right to unilaterally terminate your Marketplace Retailer Agreement with no cost or penalty to Walmart regardless of any other provision in the Agreement. 

Additional guidelines 

• Establish and maintain an Anti-Money Laundering (AML) Program that meets requirements of the Bank Secrecy Act, meaning that you’ve designated a compliance officer to oversee your AML Program, provide your employees with ongoing training, test your AML Program through regular and independent audit, file all required regulatory reports and maintain written AML policies/procedures/controls. 

• Comply with sanctions laws enforced by the United Nations, U.S. Treasury’s Office of Foreign Assets Control (OFAC), and additional applicable local economic sanctions laws and regulations to prevent illegal transactions with sanctioned people, entities or geographies within Walmart Marketplace. 

• Inform Walmart within 10 business days of any adverse regulatory action taken against you with respect to AML or OFAC matters (or any less than satisfactory assessment of your AML Program or OFAC Program by a regulator or independent third-party). 

As a seller of covered goods, you represent to Walmart Marketplace that: 

• AML and OFAC programs will be maintained as described above and in accordance with U.S. law and federal regulations. 

• You will indemnify Walmart for any damages incurred due to failure to maintain sufficient AML and OFAC programs by you and your business. 

Additionally, you agree to: 

• Work together with Walmart in good faith across all applicable markets to identify, investigate and perform due diligence on potentially fraudulent, unusual, unlawful or suspicious activities. 

• Share all data concerning such activities with Walmart, upon request, to the fullest extent permitted by law. 

• Promptly notify Walmart upon discovery of any attempted or completed transaction within the Walmart Marketplace in violation of any sanctions regulation. 

• Inform Walmart within 10 business days of any adverse regulatory action taken against you and your business with respect to AML or OFAC matters or any less than satisfactory assessment of your AML Program or OFAC Program by a regulator or independent third-party. 

• Provide information to Walmart and comply with controls as required by Walmart’s AML Program including but not limited to:  

• Personally identifiable information for beneficial owners, controlling persons and compliance officer. 

• Restrictions or suspensions regarding sales within the Walmart Marketplace. 

• Transaction limits.  

• Delayed or canceled transactions.