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Ethics Cross-Selling

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 3 – Gaming

This week I am 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 very large...more

Thomas Fox - Compliance Evangelist

Wells Fargo Settlement: Part 2 – Cross-Selling

This week I am 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 very large...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

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

The Volkov Law Group on

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

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)

The Volkov Law Group on

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

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

The Volkov Law Group

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

The Volkov Law Group on

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 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

Thomas Fox - Compliance Evangelist

Wells Fargo Week: Part IV – Senior Management, the Board and Corporate Governance Issues

At least he fessed up that it was not the (non) rogue 5,300 employees that were responsible for defrauding Wells Fargo customers. At the Senate Banking Committee hearing, held on Tuesday 20th September, Wells Fargo Chief...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 II: Tones at the Tops

Tone at the top is the single most ubiquitous phrase in compliance. However, I heard it phrased in a manner last week which not only made sense but explained why it is the most used phrase. It came from Vanessa Rossi, FCPA...more

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