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The Volkov Law Group

Wells Fargo Fumbles Sanctions Compliance Demonstrating An Absence of Culture of Compliance (Part II of II)

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Not that I am a glutton for punishment, but I always find enforcement actions to supply a number of valuable lessons learned. There are always instructive nuggets of information, opportunities missed, and root causes that...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

The Volkov Law Group

Incentives and Disincentives as the New Engine of Effective Compliance (Part I of III)

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Some were surprised by the recent move by the Department of Justice in focusing on the importance of incentives and disincentives as an important factor in an effective ethics and compliance program. Others, however, had been...more

Thomas Fox - Compliance Evangelist

A Reminder on Wells Fargo and Compensation Incentives

Carrie Tolstedt was recently in the news again. Remember her? She was the chief architect of Wells Fargo’s strategy to get customers to purchase as many products as could be rammed down their throats. Recently a federal...more

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

The Volkov Law Group

Episode 127 -- Deep Dive into the OCC Enforcement Action Against Wells Fargo CEO and Senior Executives

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In a comprehensive enforcement action, the Office of the Comptroller of Currency (OCC) announced a $17.5 million settlement with former Wells Fargo Bank CEO John Stumpf for his role in the sales practices misconduct scandal....more

Thomas Fox - Compliance Evangelist

Farewell to the Easy Rider and How to Scandal Proof Your Company: Part 1

Fonda’s life informs today’s blog post as we begin a multi-part series based upon the recent Harvard Business Review (HBR) Spotlight on White Collar Crime. Today, we begin the article by Paul Healy and George Serafeim,...more

Thomas Fox - Compliance Evangelist

Doing Business with Wells Fargo – Watch Your Wallet

You really do have to appreciate Wells Fargo & Co. Perhaps solely of the most recent spate of US corporate ethics scandals, it is the company that keeps giving and giving and giving. On the other hand, it may simply be that...more

Thomas Fox - Compliance Evangelist

Compliance into the Weeds: Episode 117-Wells Fargo Update

Compliance into the Weeds is the only weekly podcast which takes a deep dive into a compliance related topic, literally going into the weeds to more fully explore a subject. In this episode, Matt Kelly (the coolest guy in...more

The Volkov Law Group

Financial Institutions and the Glaring Absence of an Ethical Culture

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Federal prosecutors and regulators have been active in tackling US banks. In the last few weeks, the Federal Reserve took the extraordinary step of blocking Wells Fargo’s ability to grow its business until it improves 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

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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

The Volkov Law Group

Poor Performing CEOs and Boards and Compliance Disasters

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The business headlines are filled with the latest corporate scandal – Uber’s defective culture, CEO misconduct and reprehensible comments by supervising board members. Uber is just one of several significant companies caught...more

Thomas Fox - Compliance Evangelist

Unfair and Unbalanced-Episode 18

In this episode, Roy Snell and myself discuss how incentives are integral to the compensation plans of a wide range of workers. Many experts point to their value in rewarding behavior that is in the interest of the...more

Thomas Fox - Compliance Evangelist

Compliance Lessons for Executive Leadership from The Wells Fargo Investigation Report

Compliance lessons from truly one of the most damning reports of complete corporate failures around ethics and culture that has recently been seen....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

Lewitt Hackman

Whacky Employment Claims: Who's Whackier? Management or the Employee?

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As employment defense attorneys, we see many strange situations arise in the workplace. The question is, how prepared are you as an employer to handle the wackiness that may potentially arise when your employees make...more

JD Supra Perspectives

Focus On Enabling Your People, Not Controlling Them, To Create an Effective Compliance Culture

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When employees of all levels believe in and support policies and standards, that’s when you see real compliance. In-house perspective from NetApp GC, Matt Fawcett....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

When Business Supersedes Compliance – A Recipe for Disaster

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When looking through the wreckage of a major corporate compliance disaster, it is relatively easy to spot the important events when business needs (or money) are consciously elevated over compliance concerns or even...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

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