When discussing the effectiveness of compliance programs, among the most effective learning tools are examples of either immense success or dismal failure.
It is a widespread practice to study enforcement actions for clues on what a company or its leadership did wrong. It is not so much an exercise in schadenfreude as an opportunity to learn more about what went wrong, how a regulator uncovered the malfeasance and responded, and whether the whole affair might have been averted in the first place with better controls or policies.
