One of the most important aspects of any compliance program is trust. People like Barbara Brooks Kimmel, CEO and Cofounder of Trust Across America-Trust Around the World, take this a step further, advocating trust as a business imperative. It is certain however that if your stakeholder constituents have no trust in you, you cannot depend on them to help an internal investigation. That is the situation being played out now by the United States Olympic Committee (USOC) as it tries to recover over the debacle in its gymnastic program and its former team doctor Larry Nassar.

Allegations of sexual abuse by Nassar towards the gymnasts was put forward to the USOC in 2015, and the organization apparently did not investigate them. Worse, one former gymnast, Olympic gold medal-winning gymnast McKayla Maroney sued the USOC and others in December, alleging the organization had lied about when it learned of the allegations against Nassar. One report said that the USOC had known about the allegations for 31 months and had basically done nothing about 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...