As sure as I write this, someone is out there saying that ‘tone at the top’ is one of the most overblown phrases in compliance. Yet if there is one truism about business, a company’s culture really does start at the top. While Enron did not enshrine that truism, it certainly still remains a potent example. If you put criminals in at the top, the rest of the company will be just as rotten.

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...