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White Collar Crimes Fraud Corporate Culture

Society of Corporate Compliance and Ethics...

The Dark Patterns Behind Corporate Scandals

Professors Guido Palazzo and Ulrich Hoffrage are skeptical. When they hear that there was a bad apple at the core of a scandal, they are hesitant to accept that explanation. Instead, they argue in this podcast and in their...more

Latham & Watkins LLP

Recent Developments for UK PLCs - December 2024

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On 15 November 2024, the FCA released Primary Market Bulletin 52, offering guidance on compliance with MAR and DTR requirements, particularly in identifying and disclosing inside information, managing shareholder...more

Thomas Fox - Compliance Evangelist

Culture Week: Part 3- A Toxic Culture and the Fraud Triangle

We continue our exploration of corporate culture. Today, we consider the intersection of the Fraud Triangle and a toxic culture. The Fraud Triangle is well-known to most compliance practitioners. It is pressure, opportunity,...more

Jenner & Block

Anti-Corruption Enforcement - 2021 Year in Review

Jenner & Block on

Due to the impact of the COVID-19 pandemic, and the change in presidential administrations in the United States in January 2021, US enforcement of the Foreign Corrupt Practices Act (FCPA) declined in 2021. However, we...more

The Volkov Law Group

Deutsche Bank FCPA and Fraud “Spoofing” Settlement: A Review of Deutsche Bank Conduct (Part II of II)

The Volkov Law Group on

Deutsche Bank’s ethics and compliance function faces numerous challenges.  Deutsche Bank has a storied record of scandals, government enforcement actions and failures to abide by prior deferred prosecution agreements (DPAs)....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

Foley & Lardner LLP

New Attorney General Issues Guidance on Corporate Compliance Programs

Foley & Lardner LLP on

The US Department of Justice (DOJ) Fraud Section has published new guidance for corporate entities on corporate compliance programs. The guidance, titled, “Evaluation of Corporate Compliance Programs” (Compliance Program...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

Thomas Fox - Compliance Evangelist

When the Compliance Counsel Speaks, CCOs Should Listen

I was recently having breakfast with a colleague and we were discussing the Department of Justice’s (DOJ) Compliance Counsel Hui Chen and what we believe to be the positive impact she has had on the compliance community,...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

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