Many have speculated about finding a single cause for the explosion of FCPA enforcement after 2004, including myself. The death last month of Mike Oxley, the House of Representatives sponsor of legislation known as the Sarbanes-Oxley Act of 2002 (SOX), caused me to think yet again about the variety of factors that led to this growth in enforcement.

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...