Sometimes you enter with a bang, but leave with a whimper. That is what I thought when I read in early July that the Securities and Exchange Commission had dismissed its cases against two Noble Corp. executives, Mark Jackson and James Ruehlen. The case had drawn much fanfare and attention, as it was a very rare SEC action against individuals for violations of the Foreign Corrupt Practices Act. But the case did not seem to turn out as the SEC had intended.

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...