Last week’s news that Volkswagen had summarily departed its top ethics and compliance officer was punctuated by more bad news for the company when it was reported that the company’s former chief executive Martin Winterkorn was named as a suspect in a fraud investigation brought by the German government. Through new evidence obtain in a massive culling of documents secured in sweeps through some 28 private residences and extensive interviews, the authorities “have expanded the number of suspects under investigation to 37 from 21.” This includes former CEO Winterkorn.

This will surely come as very bad news for VW, as it was beginning to pick up the pieces of its shattered reputation from the emissions-testing scandal. Earlier this month, the company had settled with the U.S. government by agreeing to plead guilty to conspiracy to defraud the U.S. government and agreeing to pay a $4.3 billion criminal fine in addition to the civil penalty of $17.5 billion from 2015.

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...