It was recently announced that Switzerland mining giant Glencore had received a subpoena from the U.S. Justice Department regarding its operations in the Democratic Republic of Congo, Nigeria, and Venezuela for possible FCPA violations. The matters under Justice Department scrutiny in the Republic of Congo are in relation to mining operations, while the matters under review in Nigeria and Venezuela is the company’s ventures in oil trading through those two energy-producing nations. The subpoena seeks information going back to 2007.

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...