In the recent Teva Pharmaceuticals FCPA enforcement action, the SEC Complaint laid out one of the best descriptions of a paper compliance program I have recently seen. To set the stage, the company had been made aware of illegal payments in its Mexico subsidiary, investigated the allegations and then fired several employees involved. The next step was for the company to upgrade its compliance program going forward.

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...