Almost never in the FCPA world do you see an announcement as stark as the one delivered this week by United-Continental Airlines around the immediate resignation of the now-former Chief Executive Officer Jeff Smisek. A company release stated: “The departures announced today are in connection with the company’s previously disclosed internal investigation related to the federal investigation associated with the Port Authority of New York and New Jersey. The investigations are ongoing and the company continues to cooperate with the government.”

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...