After holding the record for the largest corruption related fine, $2.6bn paid to three countries, for a short few months, the Brazilian construction giant Odebrecht was overtaken by the Brazilian meat processing giant J&F Investments which clocked in with a $3.2bn fine in April. The entire amount was payable to the Brazilian government and J&F may face additional penalties from other countries. But Odebrecht is not out of the woods yet, as it may face additional penalties for its Americas-wide institutionalized program of bribery and corruption.

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...