Want some early evidence of the effect of the Justice Department FCPA Pilot Program? Read nothing more than this letter send out by FCPA Unit head Daniel Kahn to both Akamai Technologies, Inc. and Nortek Inc. this week, declining to prosecute both companies. (Nortek received a similar letter.)

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...