Category: General

20 Feb, 2018

US Bancorp Pays $613 Million and Joins the Ranks of AML Violators

Prosecutors and regulators are targeting global banks. The beginning of 2018 has seen dominated by enforcement actions of financial institutions – the Federal Reserve’s unprecedented enforcement action against Wells Fargo; Rabobank’s payment of $600 million for significant AML violations; and US Bancorp’s (USB’s) recent $613 million settlement AML violations. (Documents Here). In the latest enforcement action, USB entered into a two-year deferred prosecution agreement (DPA)...

General

19 Feb, 2018

Rabobank Coughs Up $368 Million and Pleads Guilty to Conspiracy to Money Launder and Obstruct Investigation

The Justice Department announced a guilty plea by a subsidiary of Rabobank, a Dutch global bank, to a conspiracy to violate money laundering laws and obstruct a regulatory investigation of Rabobank’s activities in California. (Copy of Plea Agreement Here). Rabobank agreed to pay $368 million in forfeited funds. Rabobank’s settlement follows the deferred prosecution agreement with George Martin, a Rabobank manager in Southern California, who...

General

14 Feb, 2018

Planning for the Perilous Consequences of a Data Breach

The nightmare scenario for corporate boards and senior executives revolves around the impact of a major data breach. We have seen this first hand with Equifax, Anthem Healthcare, and Target, as prime examples. In the Equifax case alone, it is estimated that approximately 140 million individuals had their information hacked in the attack. It is easy to understand, in these circumstances, that a company can...

General

13 Feb, 2018

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

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. The Federal Reserve’s action blocking Wells Fargo’s growth is perhaps the strongest condemnation of a company’s overall leadership and direction that the government can impose. There is clearly a complete lack of...

General

11 Feb, 2018

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General

8 Feb, 2018

Local Compliance Strategies to Embrace the Business (Part II of II)

The ultimate success of a global ethics and compliance program often depends on the ability of local compliance officers to engage business operations in a specific country. Of course, a global compliance program’s performance depends on cooperation and coordination at all levels, but in many cases, the ability of a local compliance officer to adopt creative and intelligence strategies to engage the business will establish...

General

7 Feb, 2018

Challenges in Global Compliance Operations: Structure and Responsibilities (Part I of II)

Global companies face ever-increasing challenges when building and implementing global ethics and compliance programs. From my vantage point, the set of challenges can be different depending on the industry. Global regulated companies, such as pharmaceutical, medical device or financial institutions, face a different constellation of challenges than a global manufacturing company. Notwithstanding the risk and compliance differences among the specific industries, there are a number...

General

6 Feb, 2018

Resources, Resources, and More Resources – The True Test of an Effective Ethics and Compliance Program

An effective ethics and compliance program depends on the Chief Compliance Officer’s authority, independence, and resources. A company’s commitment to a compliance program requires money and employees – there is no question that words of support, organizational status in the C-Suite and a robust board reporting relationship are all important. However, all those elements are important but, in the end, those principles mean relatively little...

General

5 Feb, 2018

“Trust Better Be Your Most Important Value” – Marc Benioff, Salesforce CEO

Given the turbulent times we live in, it is refreshing when we hear a corporate leader explain the importance of trust as a corporate value. Marc Benioff is the CEO at Salesforce who is aggressively pushing his company to meet a target revenue of $20 billion by 2022. More importantly, at a recent panel discussion at the Davos World Economic Meeting, Benioff gave a powerful...