- Chief Compliance Officer and VP of Legal Affairs, Arrow Electronics
By 
Aly McDevitt2020-09-14T13:00:00
Carnival’s checkered past of violating environmental laws was no secret. The company pleaded guilty in federal court both in 2002 and 2017 to illegally discharging oily waste into the seas and falsifying records of oil-contaminated bilge water to cover its tracks. The first time the transgressions were caught on several ships in the Carnival Cruise Line fleet; the second time it was an insidious issue in the Princess fleet. According to the Department of Justice, the commonalities in widespread, covert misconduct over a 25-year stretch suggested the company harbored a systemic problem of ethics and culture that was never properly rooted out.
It was an overhaul that would take time, teamwork, patience, commitment, and a good amount of ingenuity. The newly minted E&C department was tasked with uniting the operating companies’ compliance functions, developing trust and rapport with shipboard and shoreside personnel, reinventing the company’s ethical culture, and last but certainly not least, abiding by a court-mandated and supervised five-year environmental compliance plan (ECP) that included a court-appointed monitor (CAM).
The terms stipulated by the ECP were a tall order. Peter Anderson, the new chief ethics and compliance officer (CECO) and a former federal prosecutor, was confident he could turn Carnival’s compliance woes around.
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Peter Anderson, Carnival’s first chief ethics and compliance officer and a central figure in leading the cruise line giant through its environmental compliance monitorship, has resigned. Richard Brilliant, Carnival’s chief audit officer, will replace Anderson in the new role of chief risk and compliance officer.
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Cruise line operator Carnival Corp. has pleaded guilty and agreed to pay a $1 million penalty for violating a condition of its probation relating to its environmental compliance plan.
Both JPMorgan Chase and Deutsche Bank retained their respective Jeffrey Epstein relationships for too long. Yet, there is a case to be made for why exiting a high-risk relationship too soon can become an inverse form of recklessness.
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Jeffrey Epstein’s designation as a high-risk client should have subjected him to enhanced due diligence that never appeared to occur, most notably at Deutsche Bank. Instead, Epstein was allowed to continue his misconduct despite numerous red flags.
