We often hear corporations claim it was the ubiquitous “rogue employee” who was solely responsible for some corporate malfeasance. The former CEO of Wells Fargo took this position to its logical extreme when he alleged it was some 5,300 terminated Wells Fargo employees who were responsible for the system fraud engaged in by the bank for years in opening up fraudulent bank accounts and bank cards for bank customers. However The Man From FCPA rarely hears it back from the employee side. (Although one convicted FCPA felon did relate, his company’s bribery scheme was not his fault as he was only “the bag man” in paying the bribes and not the mastermind.)

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...