It was recently reported that Amazon has quietly been dipping into the banking business over the past few years, to the tune of making some $3 billion in loans to small businesses that sell through its online platform. As Amazon has led the greatest amount of disruption in first book selling, then later retail sales, in the 21st century, in addition to its corporate Web services and movie streaming, this move should bring the notice of not only banking retailers but also banking regulators.

Yet, Amazon’s move into the banking sector raises compliance lessons for The Man From FCPA, and for all other compliance professionals, as the banking sector is one of the most heavily regulated commercial sectors in the United States. Indeed, the current House of Representatives has passed legislation to make access to capital easier. Yet, Amazon was able to make this business line profitable while complying with the claimed onerous rules promulgated in the wake of the 2008 banking crisis and the passage of Dodd-Frank.

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...