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Ballard Spahr LLP

32 Attorneys General call for enactment of marijuana banking legislation

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Thirty-two attorneys general representing states, territories and Washington, D.C. are asking Congress to pass legislation to provide financial institutions a safe harbor if they provide services to marijuana-related...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

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

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

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 I – Who’s Afraid of Virginia Woolf or What is Risk?

Edward Albee died last week. To my mind he was right up there with Arthur Miller and August Wilson as one of America’s greatest playwrights of the second half of the 20th century. His works were known, as noted in his New...more

Baker Donelson

Flaws and All, CFPB's Arbitration Study Sparks Vigorous Debate over Next Steps in Regulating Mandatory Arbitration Clauses

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As expected, the reaction to the Consumer Financial Protection Bureau's (CFPB) arbitration study report, released in March 2015, has been vociferous. All sides of this important debate are loudly proclaiming that their...more

Baker Donelson

You Want to Export to Cuba? Get Ready, But You Probably Can’t Quite Yet.

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New rules came out on September 21, 2015 from both the Commerce and Treasury Departments. Although for the most part these changes only slightly broaden or clarify pre-existing exceptions to the embargo against Cuba, they...more

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