Corruption does not exist in a vacuum. It still may be possible to bribe a government official the (very) old fashioned way: with bags of cash, literally carried across a border. The much more modern equivalent is via wire transfer. A recent report spoke once again to the role of banks in modern day bribery and corruption. Without the acquiescence of these international banks, the worldwide scale of corruption might not be so great.

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...