You cannot say the government does not communicate its expectations around Foreign Corrupt Practices Act enforcement. The SEC concluded its investigation around the illegal activity engaged in by former SAP International Vice President of Global and Strategic Accounts, Vicente Garcia, for bribery and corruption in sales to certain government officials in Panama; all in violation of the FCPA. This enforcement action presents some clear signs about where FCPA enforcement will be headed into 2016 and beyond.

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...