Even with a great tone-at-the-top and in the middle, you cannot stop. One of the greatest challenges of a compliance practitioner is how to affect the “tone at the bottom.” Employees often look to their direct supervisor to determine what the tone of an organization is and will be going forward. Many employees of a large, multinational organization may never have direct contact with the CEO or even senior management. By moving the values of compliance through an organization into the middle, you will be in a much better position to inculcate these values and operationalizing compliance with them.

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...