Sometimes The Man From FCPA really does wonder what the U.S. Justice Department and the U.K. Serious Fraud Office (SFO) can do to get the message out that it is illegal to pay bribes, even right up to the very top of an organization. This past week, the Australian mining giant Rio Tinto announced that it had terminated two top officials after an investigation into payments to a third party to obtain mining rights in the notoriously corrupt country of Guinea. As reported by the Wall Street Journal, the company terminated energy and minerals chief Alan Davies, as well as head of legal and regulatory affairs Debra Valentine, following an internal investigation.

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...