The scourge of money-laundering seems almost unending. In recent years it has engulfed numerous international institutions. For the past several years, even the Vatican has had to face this issue. The Church’s bank, known formally as the Institute for Religious Works (IOR) had been roundly criticized by Italian prosecutors for both its failure to carry out appropriate due diligence over its customers and its inability to track suspicious transactions. Indeed in an article in the Financial Times it was reported that the Vatican’s early efforts to fight this problem were criticized by the European Union Moneyval, its anti-money laundering monitoring body.

Thomas Fox has practiced law for over 40 years. Tom writes the daily award-winning blog, the FCPA Compliance and Ethics blog and founded the Compliance Podcast Network. Tom leads the discussion on AI in...