You know it is going to be a bad day when you see your company’s name splashed across a BBC investigative report into alleged payment of bribes to secure business contracts. However, your day can get considerably worse when US congressmen, call for the Justice Department to investigate your company for possible violations of the Foreign Corrupt Practices Act. Unfortunately for the British company British American Tobacco (BAT) both these eventualities have recently occurred.

Back in November, the BBC investigative television program Panorama claimed it had found evidence of bribery at one of the UK’s biggest companies. The program interviewed for former BAT employee, Paul Hopkins who said that BAT had illegally paid politicians and civil servants in countries in East Africa. The BBC report claimed there were documents which indicated BAT may have paid people off to protect its corporate reputation and cover up scandals like environmental damage caused by a warehouse fire in Uganda, and even engaged in corporate espionage and sabotage of competitor tobacco corporations in Kenya.

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...