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.

As reported in the Wall Street Journal, the company was fined a record $8 million for falsifying audit reports, altering documents, and then providing false testimony under oath to the regulatory oversight board. The PCAOB sanctioned 12 former partners in the firm. In a statement by Claudius Modesti, director of enforcement at the PCAOB, said, “This is the most serious misconduct we’ve uncovered. It’s cover-up after cover-up after cover-up.” Separately, the PCAOB fined Deloitte’s Mexico affiliate $750,000 to settle allegations it had not taken proper steps in documenting its audits.

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...