Many Europeans wonder why the U.S. Justice Department does not prosecute foreign officials who receive bribes in violation of the FCPA. The reason is that the FCPA is a supply-side law, which (unlike the U.K. Bribery Act), does not criminalize the receipt of bribes; only the payment of them. Some commentators claim this opens a gap in U.S. enforcement efforts towards the international fight against bribery and corruption.

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...