The Man From FCPA has long railed against the ‘Myth of the Rogue’ employee. Other commentators say is it simply unfair to punish a lillier-than-white corporation for the actions of a few employees, usually at disparate locations scattered across the globe, for actions in which the corporation profits. However, I now understand why it is always the employees fault when a corporation engages in fraudulent activity leading to regulatory fallout. The CEO of Wells Fargo has explained it to me.

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...