What makes a fraudster? Indeed what would allow a person to knowingly violate the Foreign Corrupt Practices Act? The Man From FCPA considered these questions when reading a recent New York Times article, which noted that: “people who tell small, self-serving lies are likely to progress to bigger falsehoods.” Most interestingly the research on which the article was based went on to note “the brain appears to adapt to the dishonesty.” This certainly has some very interesting implications for anti-corruption compliance programs.

Academics, such as Kelly Richmond Pope from DePaul University, who consider fraud and fraudsters from the academic research perspective, have been saying basically the same thing for some time. Fraudsters usually start with small frauds and they may even feel uneasy or bad when engaging in such activity. Yet over time, they appear to become more desensitized to the fraud. It thereby becomes easier and easier to commit the fraud. All of this is usually made even more justifiable, when in the FCPA context, the fraudsters justify that their actions are not done for their personal benefit but for the greater good of the company.

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...