The greater international anti-corruption world was stunned earlier this year when the Brazilian meat-packing giant JBS paid $3.2bn to settle its massive bribery and corruption scheme that netted over 2,000 politicians in their corrupt web. There was much criticism at the time that the two leaders of the company, brothers Joesley and Wesley Batista got off scot free, with Wesley staying on as CEO of the disgraced company. Yet, the brothers could not seemingly control themselves with the sweetheart deal.

First was the nearly four hour recording of brother Joesley bragging about how he omitted evidence when presenting testimony to prosecutors. Somehow this recording was then turned over to prosecutors who revoked Joesley’s immunity and plea agreement which had kept him out of jail.

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...