When commentators consider endemic corruption they are usually considering a plethora of rules and regulations that allow low-level government functionaries to hold their collective hands out. This attitude in turn then permeates the entire culture, whether directly from the government or in a state-owned enterprise. One of things becoming apparent in the ever-burgeoning Brazilian corruption scandal, however, is that access to capital can be a prime mover in creating endemic corruption. To overcome such a structural component, it may require a radical reordering of Brazilian political structures.

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...