The Evaluation of Corporate Compliance Programs makes clear that a company must have more than simply a good โ€œTone-at-the-Topโ€; it must move down through the organization from senior management to middle management and into its lower ranks. This means that one of the task is to get middle management to respect the stated ethics and values of a company, because if they do so, this will be communicated down through the organization.

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...