Perhaps the most ubiquitous phrase in compliance is “tone at the top.” From the Justice Department to the U.K. Ministry of Justice to the OECD, every commentary on an anti-corruption compliance program says that it all starts with the senior leadership of an organization and most specifically a CEO. This has led many organization to consider not only what a CEO says but how he or she comports themselves to be indicative of how they might run an organization. This type of analysis speaks to a leader’s character. There is, however, a second and equally important trait for every CEO—and that is judgment. Unfortunately, judgment does not always get as much due diligence and research as character.
