The Man From FCPA, like some 143 million others in the United States is now looking at his most sensitive personal and financial data being floating through the ethisphere of stolen data, after the data breach at Equifax. To say the breach and the company’s response have been something less than sub-optimal would seem to be one very large understatement. Further the senior executives’ sale of company stock shortly after they had knowledge of the breach but before the information was made public might seem like a tailor-made case of criminal insider trading. The overall legal liability of the company could simply be staggering. The largely self-inflicted public relations disaster which has befallen the company is only in its opening stages.

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...