One of the most ubiquitous phrases in compliance and indeed all of corporate governance is โ€œtone at the top.โ€ 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.

Valeant is just the latest in a string of companies that found when you bend the rules, lie and cheat your way to enormous profits; when it falls, it falls hard. Beginning last fall when an accounting scandal blew forth from a pharmacy chain controlled by Valeant (off the books entities-in Houston that sounds eerily familiar) up through this spring, the companyโ€™s value dropped from $90bn to $10bn. Its (now) former CEO Michael Pearson was credited from the companyโ€™s spectacular growth until it all came crashing down.

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...