I'm tired of 'tone at the top.' Sometimes I wish Boards and CEOs would just stop talking and do.

Every company has the type of compliance program it wants. The deciders decide on how to allocate resources and position their chief compliance officer, and the result reflects their priorities.

The rising chief compliance officer lifts all boats.

The Chief Compliance Officer reporting to the General Counsel can work great, until it doesn't.

Retaliation is a company felony because it works like a cancer on the culture of the organization.

A true ethical culture reflects the better instincts of company leadership, and retaliation does the opposite.