If you have done business in Saudi Arabia or with wealthy Saudis over the past few years, now might be a very good time to review not only those business relationships, but also your FCPA compliance program. Since November, the current Saudi Arabian government has had billions of dollars transferred to it by very wealthy, connected Saudi businessmen through hook, nook, crook, and perhaps a fair amount of coercion.

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...