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.

Does it matter how quickly you get the contract or how the investigation is closed, or is there another analysis to take into consideration?

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...