For any company going through an FCPA investigation, perhaps the most dreaded question is “where else?” as it imports there may be corruption issues in other locations, literally across the globe. For Uber Technologies, however, the recurring question is “what else?” and it was once again brought to mind when the latest negative revelation from Uber was released. This time it was a payment to hackers who broke and stole confidential data of some 57 million Uber customers and drivers.

In 2016, the company was hacked with customers’ credit card, password, and other information being stolen. Potentially worse was the theft of Uber drivers (recall Uber does not classify them as employees) state driver’s license numbers and other sensitive employment information. This is on top of its current legal problems including a potential ban of Uber in London, the alleged theft of trade secrets over driverless car technology from Alphabet’s Waymo, its Greyball software program, designed to evade regulatory review, and ongoing FCPA investigation(s).

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...