Wells Fargo cannot seem to get out of its own way to begin to move forward. Now, the bank is facing a whistleblower lawsuit and investigation by the Consumer Financial Protection Bureau for closing fraud victims’ accounts without investigating potential criminal activity, a violation of law.
Tom Fox
Thomas Fox has practiced law for over 40 years. Tom writes the daily award-winning blog, the FCPA Compliance and Ethics blog and founded the Compliance Podcast Network. Tom leads the discussion on AI in compliance through his best-selling book Upping Your Game. He has 38 other books on the use of AI in compliance and business ethics, leadership including the seminal work, The Compliance Handbook, with its 7th edition coming out in 2025. He is the founder of the award-winning Compliance Podcast Network.
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Posted inAnti-Bribery
What has Latvia wrought?
U.S. banking regulators have long understood the connection between bribery, corruption, money laundering. and security. It will be interesting to see if the ECB and European countries are willing to become as aggressive as their U.S. counter-parts in fighting the global scourge of money laundering.
Posted inBoards & Shareholders
OIG guidance for boards on compliance
It turns out that 2015 guidance from the OIG provides an excellent roadmap in today’s world for how companies can structure a compliance committee for their board and for the board’s obligations.
Posted inBoards & Shareholders
Board’s prudent discharge of compliance obligations
A look at how board members might want to enhance their prudent discharge to shareholders in regard to the FCPA, as the SEC and Justice Department could be giving it their full attention.
Posted inEthics & Culture
Loss of trust and internal investigations
If your stakeholders do not trust you, they will not confide in you in a meaningful manner. Many commentators talk about business ethics, but it may all start with business trust.
Posted inTechnology
Social media basics for the CCO
Building a robust Twitter feed is a must-have in every compliance toolbox. As such, compliance professionals need to brush up on social media.
Posted inAnti-Bribery
Former PdVSA officials face corruption-based civil lawsuit
A look at the first civil action filed in Houston for the massive PdVSA bribery and corruption that engulfed the company and those who tried to do business with it over the past few years.
Posted inAnti-Bribery
Bad days ahead for Shell and ENI?
The bribery allegations against Shell and Italian energy company ENI makes one wonder: If monies paid to a foreign government itself are now subject to scrutiny, could it open up an entirely different exposure to liability for international organizations?
Posted inAnti-Bribery
Facilitation payments under the FCPA
In addition to its restrictions, a key to FCPA compliance is accurately recording facilitation payments going forward. As with all things FCPA-related, the “document, document, document” mantra holds.
Posted inAnti-Bribery
Extortion policies under the FCPA
An extortion payment, while not a violation of the FCPA, should have its own set of policies and procedures that employees adhere to per the chief compliance officer.
