What is the cost of corruption? How much due diligence must you perform with those entities that are your customers? Does doing business with companies that have a propensity for corruption put your company at risk even if your business not does not engage in such behavior and has a best practices compliance program in place?

I thought about all those questions and others when I read a recent piece in the Financial Times (FT) Lex column, entitled โ€œPetrobras: rip tide.โ€ The ongoing woes for the company, and indeed the entire country, around โ€œJavo Litoโ€ or Operation Car Wash are well known. Many companies have been dragged directly into the scandals or, at the very least, have been required to look more closely at their own commercial operations with Petrobras and Brazil more generally.

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...