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...
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...
In an extraordinary action, with significant ramifications for the financial industry, the Federal Reserve recently announced a series of enforcement actions against Wells Fargo. On Friday, February 2, 2018, which was then-Chairwoman Yellen’s last day in office, the Federal Reserve announced an enforcement action against Wells Fargo for its corporate governance failures and poor record of remediation. (The Press Release and Enforcement Documents are Here)....
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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...
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...
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...
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...
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 its reputation, and raise a host of legal and reputational problems. I have written numerous times on the importance of assessing C-Suite risks and building compliance and financial...
The New York Department of Financial Services has adopted detailed cybersecurity regulations for financial institutions. (Here). The NYDFS has filled a vacuum created by the failure of the federal government to act in this important area. Congress has failed to enact any specific requirements; the federal government continues to rely on voluntary efforts and recommended standards. As long as this vacuum continues, state regulators and...
