One of the areas in the fight against bribery and corruption that regulators are beginning to focus on is the role of banks in facilitating such transactions. I thought about this connection when I read a recent article in the Financial Times about the banks now caught up in the FIFA corruption scandal. Numerous banks, such as BNP Paribas, JP Banamex, HSBC, Standard Chartered and UBS have paid heavy fines for failures around anti-money laundering controls and now some of these banks are in talks with the Justice Department about what they knew and when they knew it (sound familiar?) in connection with the FIFA 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...