Just as the myth of the rogue employee is simply that, a myth; there is always another side to corruption. In a bribery case there is a bribe payor and a bribe receiver. While the FCPA does not make illegal the receipt of bribery-infused monies, there are other weapons in the Justice Department such as money-laundering, which can lead to the prosecution of bribe receivers. The Man From FCPA considered this less-well-traveled prosecutorial path when reading recent reports about the investigations into Robert Bosch GmbH and its U.S. subsidiary.

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...