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Compliance Cross-Selling

Compliance programs typically refer to formalized institutional procedures within corporations and organizations to detect, prevent and respond to indvidual and widespread instances of regulatory violations. ... more +
Compliance programs typically refer to formalized institutional procedures within corporations and organizations to detect, prevent and respond to indvidual and widespread instances of regulatory violations.  In response to many corporate scandals evidencing rampant unethical business practices, many nations, including the United States, began passing strict regulatory frameworks aimed at curbing these abuses. Notable pieces of legislation in this area include the U.S. Foreign Corrupt Practices Act (FCPA), Sarbanes-Oxley (SOX), and the U.K. Bribery Act, to name a few. The foregoing statutes and the severe penalties often associated with them form the basis of many modern institutional compliance programs. less -
Thomas Fox - Compliance Evangelist

Compliance in the Hundred Acre Wood: Tigger and Sales Incentives

This week I begin a five-part series on compliance as seen through the lens of Winnie the Pooh and the characters who live in the Hundred Acre Woods: Pooh, Eeyore, Tigger, Kanga & Roo, and Piglet. Winnie-the-Pooh, also called...more

Thomas Fox - Compliance Evangelist

Wells Fargo Settlement: Part 4-Why Would You Ever Do Business with Wells Fargo again?

This week I have been exploring the Wells Fargo Department of Justice (DOJ) and Securities and Exchange Commission (SEC) settlement of $3 billion. The case presents multiple lessons for the compliance professional and one...more

The Volkov Law Group

The Dangerous Mix of Incentives and “Misconduct”

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We often hear about the dangerous risk to a company’s culture from rigorous sales incentive programs.  Like most issues, the answer to this issue is not cut and dried....more

Thomas Fox - Compliance Evangelist

Nights in White Satin – The Continued Pain at Wells Fargo

The Wells Fargo scandals continue to be one of the starkest lessons about the cost of a corrupt culture and the catastrophic effect it can have on an organization. The former Chief Executive Officer (CEO) and head of the...more

The Volkov Law Group

The Long Road Back to Redemption: Wells Fargo’s Path to Remediation (Part II of II)

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Wells Fargo’s ability to grow its business is on hold for a year while it designs and implements a remediation program to address deficiencies in its board governance, risk management and compliance program. ...more

The Volkov Law Group

Federal Reserve Hits Wells Fargo with Unprecedented Enforcement Action (Part I of II)

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In an extraordinary action, with significant ramifications for the financial industry, the Federal Reserve recently announced a series of enforcement actions against Wells Fargo....more

Thomas Fox - Compliance Evangelist

Memo: Wells Fargo, Put a Compliance Professional on your Board

After almost two years, you might think that Wells Fargo, its senior management and Board of Directors would have gotten the message from its regulators to take its compliance obligations seriously, remediate and put ethics...more

The Volkov Law Group

Tales from the Corporate Scandal Crypt: GM, VimpelCom, VW and Wells Fargo

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We are fascinated by corporate scandals. Since the 1980s, the US public has enjoyed unraveling corporate scandals, and vilifying corporate leaders caught in the web of deceit and misconduct. I am sure there are historical...more

Thomas Fox - Compliance Evangelist

Farewell to J. Geils – Final Compliance Function Lessons from Wells Fargo

You may not recognize the full name, John Warren Geils Jr., but you probably do recognize the name J. Geils, as in the J. Geils Band, who died this week. J. Geils was ubiquitous in the 70s and early 80s with, as noted by an...more

Thomas Fox - Compliance Evangelist

Sunshine Superman – When Culture is Not My Problem

Today we honor folk-rocker Donovan and his signature song Sunshine Superman, which was profiled in the Wall Street Journal (WSJ) column Anatomy of a Song. The song was a love paean by the singer to “Linda Lawrence, his love...more

The Volkov Law Group

Wells Fargo’s Desperate Need for a Compliance and Business Ethics Function (Part III of III)

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While reading the independent directors’ report on the Wells Fargo sales incentives scandal, you will be overwhelmed by the feeling of frustration. At the same time, what is described in the report is the extent to which...more

Thomas Fox - Compliance Evangelist

Hotel California and Wells Fargo-You Can Check Out, But Can You Leave?

Today, we celebrate The Eagles most famous song, Hotel California. It all started with a Don Felder cord progression and according to the Financial Times (FT) column The Life of a Song, it had a “fusion of Hispanic melody and...more

The Volkov Law Group

The Axe Falls on Wells Fargo – A Scathing Independent Report (Part II of III)

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In a scathing report, the independent directors at Wells Fargo released their findings and actions based on a comprehensive internal investigation of Wells Fargo’s sales abuses. Based on its findings, Wells Fargo’s...more

Thomas Fox - Compliance Evangelist

When Will Shareholders Force Boards to Do Compliance?

Today we honor one of the most iconic moments of World War II (WWII) and one of the most famous photographs of all time, that of the Marines raising the US flag on Mount Suribachi on the island of Iwo Jima. Marine...more

Thomas Fox - Compliance Evangelist

Spikes in Sales and Compliance

What is risk and how should it be evaluated? What is the data that should be reviewed to determine if an increase in sales is based on unethical or even illegal behavior? Finally, what happens when you migrate company...more

Thomas Fox - Compliance Evangelist

Sir Neville Marriner: Is Compliance Driven by What You Inspect?

Sir Neville Marriner died on Sunday. For any aficionado of classical music, Marriner’s contribution to the genre was immense, having founded the chamber orchestra, Academy of St. Martin’s in the Fields in 1958. The group was...more

The Volkov Law Group

Who is Responsible for a Company’s Mood in the Middle? – the Wells Fargo Fiasco

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Wells Fargo’s cultural tone is not easily segregated between “top,” “middle” and “bottom.” Despite the recent cross-selling scandal, in which the CFPB led an enforcement action whose fines total a whopping $185 million,...more

Thomas Fox - Compliance Evangelist

Wells Fargo Week, Part III-the Bank Knew All Along

You know it is going to be a very bad day when, as a company’s Chief Executive Officer (CEO), you receive a letter asking the following, “Specifically, the committee should thoroughly examine this issue, including: How it is...more

Thomas Fox - Compliance Evangelist

Wells Fargo Week: Part I – Who’s Afraid of Virginia Woolf or What is Risk?

Edward Albee died last week. To my mind he was right up there with Arthur Miller and August Wilson as one of America’s greatest playwrights of the second half of the 20th century. His works were known, as noted in his New...more

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