The Man From FCPA has seen some egregious cases of bribery and corruption across the globe. Yet even the enforcement action announced this week involving the Big Four accounting firm Deloitte and its Brazilian arm seems far beyond the pale. It certainly begs the question of who watches the watchers. Fortunately in the United States, when it comes to public accounting, it is the Public Company Accounting Oversight Board.

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...