FIFA seems to be getting serious about the perception that its organization is rife with corruption. Last week it suspended three of its top officials: President Sepp Blatter, Vice President Michael Platini, and Secretary General Jéôrome Valcke. All of the suspensions were for 90 days. Additionally a fourth FIFA official, Chung Mong-joon, was barred from the sport for six years over ethical violations surrounding the selection of the sites for the 2018 and 2022 World Cups.

Blatter, in his appeal of the suspension, seemed to indicate that he believed the sanction was based upon the investigation opened up by the Swiss attorney general’s office into two events. The first was over a payment approved by Blatter to Platini in 2011, for work Platini had performed some nine years earlier. The second involved Blatter’s role in awarding the television rights to the 2010 World Cup to then-FIFA board member Jack Warner. Warner later resold the television rights at a higher price than he paid for them. (Warner was one of the 14 individuals indicted by the US Justice Department for accepting bribe payments.) Platini and Valcke have also appealed their suspensions.

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...