On a number of occasions I have been brought in to lead projects addressing recently discovered. We will discuss a number of these as real case studies.
For each case we will look at…
There is increasing discussion that, rather than punish stockholders, individual officers should be personally held accountable for their decisions causing failures to act in compliance. Already the Sarbanes-Oxley law specifically requires that companies, including banks, have accurate financial reports as well as sound controls as required to assure the material accuracy of those reports. CEOs and CFOs have to personally sign statements to that effect and can be charged personally under some circumstances.
In my career there have been many times when I have been brought in as a consultant or a Senior Executive to take over non-compliant operations or to establish projects to fix non-compliant operations. Sometimes this happened after a specific executive was fired. At other times, we were able address the problems in time to avoid ending anyone’s career.
It is said that a smart person learns from their mistakes; but a wise one learns from others’ mistakes. This is a chance to learn from many other people’s hard experience.
The level of fines levied against banks resulting from failure to comply with various regulations has soared, reaching into the billions of dollars in individual instances. Every bank is responsible for compliance with a wide variety of regulations. Compliance failures are risks to both their reputation and their stockholders money.