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Corruption Tone At The Top

Thomas Fox - Compliance Evangelist

Tone at the Top Week: Part 3-Email as a Strategic Compliance Tool

We continue our exploration of how CEOs and senior executives are uniquely positioned to drive home the importance of ethical behavior and adherence to compliance regulations. Today, we consider the humble email and how it...more

The Volkov Law Group

Carrie Tolstedt, former Wells Fargo Community Banking Head, Agrees to Plead Guilty and Pay a $17 Million Fine for Obstruction of...

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If there ever is an example of a rotten corporate culture, Wells Fargo sits at the head of the class.  Since Wells Fargo’s sales pressure scandal, Wells Fargo has continued to suffer from a string of scandals and misconduct. ...more

Society of Corporate Compliance and Ethics...

[Event] 11th Annual European Compliance & Ethics Institute - March 20th - 22nd, Amsterdam, Netherlands

In-person is back! Join us in Amsterdam for the 2023 European Compliance & Ethics Institute! Strengthen your compliance and ethics program by attending our 11th annual European Compliance and Ethics Institute, 20-22 March...more

The Volkov Law Group

The Impact of a New CEO

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Businesses have to evolve in order to respond to the market, consumer demands, societal pressures and stakeholder expectations.  Companies grow and pivot in two ways – organically or through acquisition or sales of parts....more

Thomas Fox - Compliance Evangelist

Wells Fargo Settlement: Part 1 – It’s Even Worse Than Imagined

I did not think that the Wells Fargo fraudulent accounts scandal could get worse for the bank. Boy was I wrong. Last week, in a Press Release, the Department of Justice (DOJ) announced a that Wells Fargo & Company and its...more

Thomas Fox - Compliance Evangelist

Tribute to The Boys of Summer and Toxicity in Houston

The Houston Astros sign-stealing scandal filled out quite a bit last week with two significant new items. The first was an interview on the MLB Network by Tom Verducci, of disgraced Astros manager A.J. Hinch (Hinch...more

The Volkov Law Group

A Speak Up Culture Depends on Follow Through and Accountability

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Corporate leaders often talk to the talk when it comes to a Speak Up culture.  In theory, many business leaders can articulate their commitment to a Speak Up culture by emphasizing the importance of employees raising...more

The Volkov Law Group

Turning a Turbulent Social and Political Environment into Positive Ethical Culture Strategies

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Corporate cultures do not operate in a silo or free from external influences.  Yet again, another profound grasp of the obvious.  Employees, managers and senior leadership all bring their own experiences, perspectives,...more

The Volkov Law Group

The Importance of Whistleblowers to a Speak Up Culture

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The twist and turns of our political world amid the ongoing controversy surrounding whistleblower reporting has focused  attention on an important issue – encouraging whistleblowers as part of a speak up culture and...more

Thomas Fox - Compliance Evangelist

Preventing White Collar Crime

I conclude my short exploration of the recent set of articles in the Harvard Business Review (HBR) White Collar crime special section. Today, I want to look at an article by Mary Jo white, entitled “What I’ve Learned About...more

Thomas Fox - Compliance Evangelist

Antitrust Compliance Programs: Part 4 – Sentencing Considerations

As the third in a triumvirate of releases on compliance programs, the Department of Justice (DOJ) Antitrust Division released its Evaluation of Corporate Compliance Programs in Criminal Antitrust Investigations(Antitrust...more

The Volkov Law Group

When Your CEO Just Does Not Get It

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There are a lot of talented CEOs. Some remarkable leaders, innovators and eloquent spokespeople for their companies. In several recent experiences, I have been befuddled by some CEOs....more

Thomas Fox - Compliance Evangelist

Bloomsday and the Foundation of Culture

When companies come under investigation, the DOJ will ask two principal questions about the company’s compliance function. The first question is “what was the state of the compliance program at the time of the improper...more

The Volkov Law Group

Leadership Support Provides Compliance Credibility

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We often hear the compliance refrain on the importance of tone-at-the-top – meaning when the board, the CEO and senior executives demonstrate by communications and by conduct their commitment to a culture of ethics and...more

The Volkov Law Group

CEOs Under the Criminal Spotlight – More C-Suite Misconduct

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We live in a bizarre time — an information age where lines are blurred between truth and lies — a strange era in which our daily doses of information are dominated by scandals, corruption, and repeated claims of “fake news.” ...more

The Volkov Law Group

Corporate Attitudes: When Speak Up Means Keep Quiet

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As parents we all have been through the following scenario – we encourage our children to communicate and voice their concerns and to learn to articulate, reason and understand perspectives. So, our kids start to speak up...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

Criminal Enforcement Against Senior Executives: The Fish Rots from the Head

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The compliance community is well aware of the risks in the C-Suite. As you move up the corporate ladder, the level of risk from executive misconduct increases. A rotten executive can quickly bring down a company, destroy...more

Thomas Fox - Compliance Evangelist

Convergence of Cultural Styles to Move the Needle Forward

I continue my exploration of how to change the culture in an organization based upon a series of articles in the most recent edition of the Harvard Business Review (HBR) by Boris Groysberg, Jeremiah Lee, Jesse Price and J....more

The Volkov Law Group

Three Simple Steps to Improve Your Corporate Culture

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What exactly does “corporate culture” mean?  Compliance professionals often talk about how important “tone from the top” or the “mood in the middle” is, but what does that really mean?...more

Thomas Fox - Compliance Evangelist

More Compliance Lessons from Wells Fargo-FOREX Trades

At some point, you must ask just how corrupt is an organization? What does the tone from top which says to make your numbers at all cost, translate to in operationalization? Unfortunately, we have seen yet another dramatic...more

Thomas Fox - Compliance Evangelist

Leadership Lessons from the Movies

Today, I wanted to consider some of the recent leadership lessons I have explored on my podcast, 12 O’Clock High, a podcast on business leadership. In the series, host Richard Lummis and myself, mined some of our favorite...more

The Volkov Law Group

DOJ Criminal Prosecution of Wells Fargo: What to Expect?

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Compliance and enforcement headlines have focused on the Wells Fargo scandal. And for good reason. On September 8, 2016, the Consumer Financial Protection Bureau, the Comptroller of the Currency and the Los Angeles...more

Thomas Fox - Compliance Evangelist

What Will Be the Final Fallout from Wells Fargo?

Crimson flames tied through my ears... Rollin’ high and mighty traps... Pounced with fire on flaming roads... Using ideas as my maps... “We’ll meet on edges, soon,” said I... Proud ‘neath heated...more

Thomas Fox - Compliance Evangelist

Wells Fargo Week: Part V – Compliance is the Answer

I want to end this week’s review of the Wells Fargo scandal by considering what is at issue and what is at stake in this imbroglio. Unlike a Foreign Corrupt Practices Act (FCPA) violation, Wells Fargo paid the relatively...more

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