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White Collar + Fraud + Investigations + Compliance
Wells Fargo seems to be in the hot seat again with regulators. Repeated regulatory action like this in any industry should signal that there is a lack of an effective comprehensive compliance program. The key word here is effective. Every financial institution has a written compliance program. But, this should serve as a cautionary tale about identifying consistent themes about the effectiveness of one's processes and procedures.
Sure, Wells Fargo has the attention of regulators. But, there are a few things that all institutions should likely consider. Does your institution’s 1st, 2nd, and 3rd lines of defense aggregate information in a manner that key decision makers and stakeholders can appreciate the extent of a problem? Is there a pattern in the type of behavior detected? What’s the root cause? Do you incentivize compliance? Are your staff receiving sufficient training? Are your compliance, risk and investigations groups appropriately staffed?
Partner|Denise Barnes is a former U.S. Department of Justice (“DOJ”) Trial Attorney who focuses her practice on compliance, white collar and regulatory investigations, and complex commercial litigation. She represents clients in ...