Every time The Man from FCPA thinks corruption scandals cannot get any bigger, they do. In 2012 we had the revelations about Wal-Mart and alleged corruption in Mexico. In 2013 there was GSK in China, where the first western company was prosecuted for violation of domestic Chinese anti-bribery laws. In 2014 there was Petrobras, which may yet bring down the Brazilian government. In 2015 there was FIFA, which did bring down the entrenched leadership. Now in 2016 we have Unaoil. Last week, in what can only be termed a blockbuster piece in the Huffington Post, there was a story involving the company Unaoil, which may well be one of the harbinger events in the global fight against corruption and in anti-corruption compliance.

The company, based in Monaco but incorporated in the British Virgin Islands, has done what is essentially facilitation work for a wide variety of construction and extractive mineral projects across the globe, many in countries or regions with a high propensity for bribery and corruption. Companies listed in the Huffington Post article include Halliburton, its former subsidiary KBR, Samsung, and Rolls-Royce. Countries where Unaoil did business include places such as Iraq, Kazakhstan, Libya, Syria, Tunisia, and other countries in Africa, the Middle East, and the former Soviet Union.

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...