If you are like The Man From FCPA, you greatly enjoy reading some of the world’s top business-related daily newspapers such as the New York Times business section, the Wall Street Journal and, from across the pond, the Financial Times. If you do read them with any frequency, you most certainly have noticed a huge charm offensive that’s been launched by Wells Fargo. More than two pages in each of these publications, in a section cleared marked “Advertisement,” are dedicated to the company’s effort to sell readers on the fact that it really has changed for the better from the dark days of its fraudulent accounts and other related scandals. 

With titles such as “Wells Fargo Retail Bank compensation plan eliminates product sales goals,” “Wells Fargo names new independent Board of Directors,” “2,000 new risk managers hired in the last 2 years at Wells Fargo,” “New Wells Fargo structure focuses on customer experience ‘Change for the Better,’ ” and “Year of transformation at Wells Fargo,” this tactic is clearly an attempt by the bank to tell the world that it really has turned the page on the people, corporate structure and, most importantly, the culture that allowed the scandal to take place. 

Each of the articles in the advertising piece points to a substantive change that hopefully will improve the bank’s standing with its customer base and, equally important, the regulators, in the form of the Federal Reserve Bank, which has restricted the growth of the bank until it cleans up its house. While the ads are certainly a good start and an attempt to create transparency on its improvement, the proof for Wells Fargo will be in its execution. If it fails to follow through and continue these initiatives, particularly while still under the microscope for its past sins, the regulatory and customer fallout could even be greater. 

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