How does a corporate compliance function work to prevent corruption when the customer is part of the bribery scheme? Compliance professionals should enhance their controls and oversight to both detect and prevent this new Foreign Corrupt Practices Act wrinkle, as this situation cropped up in three separate FCPA enforcement actions in 2018.

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...