The Justice Department has been continually criticized, from blog commentators to U.S. senators, for not having more prosecutions against individuals for violations of the Foreign Corrupt Practices Act.

Perhaps forgetting the Mitt Romney-ism that corporations are people too, one school of thought says that by only fining companies, the message is sent that getting caught for violations of the FCPA will simply be seen as a cost of doing business. Of course the more cynical might simply say corporations are tired of paying increasing FCPA fines.

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...