Imagine a company has a high-profile contract worth around $1 billion. Conversely, imagine there is an ongoing investigation that could cost a similar amount. Now, imagine as the company’s lawyer that you propose a ‘success fee’ of $75 million to make sure the company gets that contract “quickly,” or that the investigation is closed.

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...