Writing in a political context in the Financial Times, Janan Ganesh said that โ€œHigh office is an audit of the occupant. It brings out what is actually there.โ€ The Man From FCPA was struck by this maxim as it is also true of senior management in a business, particularly a CEO. I thought about this when considering the response by former GE, CEO Jeff Immelt about the use of ghost planes which followed Immeltโ€™s corporate jet when he traveled on behalf of the company. The idea was that he would have a second jet follow him when traveling internationally, in case his own plane developed problems. This way, he could continue without delay. But that’s a very expensive failsafe. Spendthrift, even.

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...