As the Petrobras corruption scandal moves from its initial investigative phase (focusing on the corrupt actions of Petrobras employees), to the investigation of the international companies that did business with the Brazilian national energy company, Europeans that did business with the energy giant now face some challenging decisions around the issue of self disclosure.

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...