The 2011 Haiti Teleco FCPA matter brought some of the most dramatic results of any recent FCPA matter on record.

For two of the defendants who went to trial in October 2011, it was very costly in terms of their personal freedom. After a trial, the judge sentenced Joel Esquenazi to 15 years in prison for his role in the case; his co-defendant Carlos Rodriguez was given a seven-year sentence. Both were the longest sentences ever doled out for FCPA convictions at trial or guilty pleas.

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...