- Chief Compliance Officer and VP of Legal Affairs, Arrow Electronics
By 
Aaron Nicodemus2023-02-02T19:21:00
Is a new Department of Justice (DOJ) policy focused on individual accountability for white-collar crime encouraging companies to scapegoat their employees? A recent court filing in a $6 billion corporate fraud case could give company officers some sleepless nights.
In September, the DOJ announced sweeping changes to its efforts to fight corporate crime, including new guidance regarding individual accountability, voluntary self-disclosure of violations, independent compliance monitors, and ways to strengthen and sharpen a firm’s compliance culture. Deputy Attorney General Lisa Monaco said then the agency would make individual accountability its No. 1 priority.
Claims made in federal court by a former portfolio manager at financial services firm Allianz Global Investors (AGI) could, if true, call into question the DOJ’s high ground on individual accountability. It could also serve as a cautionary tale.
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The former chief security officer of Uber Technologies was sentenced to probation by a federal court judge as punishment for his involvement in covering up a 2016 data breach that affected 57 million users.
Charlie Javice and her startup Frank allegedly convinced the country’s largest bank to pay $175 million for what largely amounted to a list of fake college students. The apparent due diligence failures by JPMorgan Chase offer a cautionary tale to compliance professionals.
The case of the Uber chief security officer found guilty by a jury on two felonies for covering up a data breach and misleading federal regulators opens up another potential individual liability issue executives handling cyber incidents face, according to legal experts.
Top-of-mind issues addressed at Compliance Week’s Third-Party Risk Management & Oversight Summit, held June 3-4 in Atlanta, included safe deployment of artificial intelligence, assessing vendor viability and sustainability, understanding the role of procurement in risk ranking, the intersection (or lack thereof) between data privacy and cybersecurity, and many others.
Anne Morriss, co-author of “Move Fast and Fix Things,” advises compliance officers to tap into curiosity, communicativeness, and comfort with discomfort to build organizational trust, fast.
Regulators and government agencies often speak to the value of empowered corporate compliance programs to advancing their mission. Why not practice what they preach by empowering compliance among their own ranks?
