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Fraud Tone At The Top

Fraud is the making of false representations or engaging in deceptive behavior in order to unlawfully secure financial or personal gain. 
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

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

Can Wells Fargo Fix its Defective Culture? (Part I of III)

The Volkov Law Group on

The more you learn about Wells Fargo’s culture problems, the more difficult the problems become. But you have to start somewhere, and assuming that Wells Fargo really is committed to addressing the serious problems they face,...more

Pillsbury Winthrop Shaw Pittman LLP

Great Expectations - DOJ holds anti-corruption compliance programs to a high standard in evaluating their credibility

On February 8, 2017, the U.S. Department of Justice (DOJ) released a list of important topics and sample questions that the Criminal Division’s Fraud Section has frequently found relevant in evaluating the adequacy of a...more

Thomas Fox - Compliance Evangelist

Like a Rolling Stone and the Failures of Internal Controls

I continue my celebration of Bob Dylan, Nobel Laureate, by reflecting on what many consider to be his greatest recording, Like a Rolling Stone. In 2004, Rolling Stone magazine named it as the greatest song of all time....more

The Volkov Law Group

DOJ Criminal Prosecution of Wells Fargo: What to Expect?

The Volkov Law Group on

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

The Volkov Law Group

After Circling the Wagons: Wells Fargo’s CEO Finally Falls

The Volkov Law Group on

The Wells Fargo scandal represents a textbook case of compliance and culture failures. Recently, the scandal and Wells Fargo’s defensive crisis management strategy resulted in CEO Stumpf’s resignation. Stumpf’s demise was...more

Robins Kaplan LLP

Your Daily Dose of Financial News

Robins Kaplan LLP on

Holding companies appear to be an important new feature of the “living will” revisions the big banks have been making in an effort to appease the Fed and FDIC’s efforts to stamp out “too big to fail” entities. The idea is for...more

Thomas Fox - Compliance Evangelist

Mary Poppins, Corporate Culture and the Board

Corporate culture is singular to companies. Yet it also varies from industry to industry. I have been considering why the Wells Fargo scandal has engendered such public outrage. You could consider many factors, such as the...more

Thomas Fox - Compliance Evangelist

Monster Movie Month: Episode I – Leadership Lessons from Frankenstein

Yes October is here in full swing and for me that means I get to pull out all the old classic Universal Studio monster movies from the 1930’s and 1940’s. This year I decided to revisit the most classic of them all,...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

Dechert LLP

SEC Issues Settled Enforcement Action Against Investment Adviser, its President and Senior Officers for Compliance Program...

Dechert LLP on

The U.S. Securities and Exchange Commission (SEC or Commission) issued a cease and desist order (Order) on June 23, 2015, against Pekin Singer Strauss Asset Management Inc. (Adviser), an investment adviser registered under...more

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