Third-party risks are well perceived to be the highest risk in an FCPA compliance program. Yet time and time again companies either fail to follow through on the full five-step third-party management, or worse yet, simple bury their collective head in the sand when it comes to corrupt actions by third parties. The New York Times recently reported on how Japan-based Olympus managed to do both.

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...