The language of the Foreign Corrupt Practices Act is clear, as it prohibits providing anything of value to a foreign governmental official or employee of a state-owned enterprise. That phrase takes on new meaning when seen in the context of a recent New York Times article about corruption in China, which recited some of the exotic items that Chinese officials had received as bribes, including the well-known favorite: meat from the tail of a crocodile.

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...