The Man From FCPA believes that compliance can best be seen as a process. It is a clear series of steps progressing along a continuum. Following these steps leads to more certainty in the process, documentation of the process, and results and then review up to and including a second set of eyesโ€”all of which form the basis of a process validation program. The same is true around investigations, under the FCPA or any other statutory scheme.

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...