Irony- (especially in contemporary writing) a manner of organizing work so as to give full expression to contradictory or complementary impulses, attitudes, etc., especially as a means of indicating detachment from a subject, theme, or emotion. Dictionary.com.

This definition sprung to mind when reports surfaced that Venezuela’s inspector general’s office recently recommended the country’s “Public Prosecutor’s Office investigate and charge five current and former executives at Petróleos de Venezuela SA, (PDVSA), for allegedly embezzling public funds by paying inflated fees for the lease of an oil rig.” Why is this ironic? It is because PDVSA is notoriously corrupt, perhaps the most corruption national energy company in the world, which is really saying something. It was so corrupt that middle level managers were reported to demand Rolex watches to schedule meetings. Talk about tone in the middle!

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...