Danske Bank, Part II: Compliance Reforms


Today let’s continue to look at the settlement Danske Bank reached with the Justice Department earlier this week, for the huge money-laundering scheme that operated from the bank’s Estonia branch in the 2000s and 2010s. I’ve been reading the plea agreement in the case, and compliance officers have a lot to consider here.  First, to…

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Wisdom From a Compliance Dinosaur


The other week I had coffee with a veteran compliance officer passing through town. This CCO has worked at numerous global organizations, some of the biggest names in his industry and to the public at large. So when my friend — we’ll call him the Dinosaur, since that’s how he described himself — started talking…

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I Talked Compliance With BlenderBot


Everyone knows I’ll talk ethics and compliance with just about anybody. So when Facebook decided to roll out its new AI-driven chatbox, of course I swung by its website and started asking the bot what it thought of corporate compliance programs.  The bot, apparently named BlenderBot 3, was launched on Monday. People can strike up…

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‘Reasonably Designed’ Programs, Part II


Our post last week about the lack of clear standards for a “reasonably designed” compliance program drew lots of comment from compliance professionals — enough that the issue deserves continued exploration, since there’s plenty more to say on the subject.  First let’s consider a concrete example of the confusion that could arise here.  Imagine your…

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Lessons From Glencore Settlement


Earlier this week Swiss commodities trading giant Glencore gave the compliance community a doozy of a corporate corruption settlement, agreeing to pay more than $1 billion to regulators around the world for bribery and market manipulation that lasted more than a decade. I’ve been sifting through the settlement documents since then and we have several…

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Some Polite Words on Testing


Gather round, corporate compliance professionals. We have another speech from a high-ranking Justice Department official about how compliance programs should work, and as usual these days, the speech is full of clues that are well worth your time and attention. The speech came from Kenneth Polite, assistant attorney general for the Criminal Division, who spoke…

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ComEd, Part II: Tone From Top, Enforcement


Today I want to return to Commonwealth Edison, the Illinois public utility trying to revamp its corporate culture and compliance program after a corruption scandal that erupted in 2020. As we sift through ComEd’s progress report on improvements it has made, let’s examine two subjects indispensable to effective compliance programs: tone at the top and…

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ComEd Gives a Compliance Update


One of the more colorful compliance stories from 2020 was Commonwealth Edison, the Chicago-based public utility which paid $200 million that year to settle corruption charges. ComEd also agreed to implement a raft of compliance program improvements — and last Friday, ComEd filed its first ethics and compliance report to talk about its progress so…

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USAA, Part II: Staffing Levels and SARs


Today I want to circle back to that civil settlement that banking regulators struck with USAA last month, where they fined USAA a total of $140 million and imposed a raft of compliance program improvements that USAA needs to make double-quick. What do those demands tell us about how corporate compliance programs should operate? First,…

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Updates on Antitrust Leniency Program


Useful news for anyone working at a company involved in an illegal cartel or other vast criminal conspiracy: the Justice Department’s Antitrust Division has updated its leniency policy for corporate offenders, with new emphasis on prompt self-disclosure of the violations and remediation to prevent repeat offenses. The Antitrust Division has long allowed the first individual…

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