One of the most ubiquitous phrases in compliance and indeed all of corporate governance is “tone at the top.” Yet by the very nature of such ubiquitousness, means there is both wide circulation and wide understanding of the term. Moreover, even if a term is overused, it does not mean that the term itself is wrong. It may simply mean there is no other phrase which so well encapsulates a concept.

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...