- Chief Compliance Officer and VP of Legal Affairs, Arrow Electronics
By 
Aly McDevitt2023-02-02T13:00:00
When news of Wells Fargo’s infamous fake accounts scandal broke in 2016, the bottom-up crisis caught the attention of Todd Hartman.
Hartman, then serving as deputy general counsel and chief compliance officer (CCO) for consumer electronics retailer Best Buy, wondered along with his team, “‘Could that happen here?’”
The Wells Fargo scandal saw employees open more than two million fraudulent deposit and credit card accounts on behalf of consumers. In the aftermath, the bank has paid billions in fines and restitution; parted with thousands of employees, including multiple chief executive officers; and is still seeking to restore its reputation.
Reacting to the news, Hartman in 2016-17 spearheaded an organizational change at Best Buy uncommon for its industry: making its compliance capability independent from its legal department and instituting an enterprise risk and compliance function. He sought to understand, “‘Do we have the structures that would always enable those communications to happen in the most complete and appropriate way?’”
THIS IS MEMBERS-ONLY CONTENT. To continue reading, choose one of the options below.
News and analysis for the well-informed compliance or audit exec. Select an option and click continue.
Annual Membership $499 Value offer
Full price one year membership with auto-renewal.
Membership $599
One-year only, no auto-renewal.
Compliance teams most often report to their firm’s legal department, our “Inside the Mind of the CCO” survey found. However, heavily regulated companies and those with fewer employees saw different trends emerge.
Compliance professionals often do not think broadly enough about what can and should fall under the umbrella of monitoring and review that will positively impact their ethics and compliance programs. Mary Shirley offers suggestions for program elements to review.
How can a company prove its compliance bona fides to a regulator, should one ever come knocking on its door? The Home Depot has prepared for such a scenario with detailed guidance pegged to the DOJ’s “Evaluation of Corporate Compliance Programs.”
When the DOJ released its revised Evaluation of Corporate Compliance Programs, it turned some heads. Tucked into a section on risk assessments was a strongly worded series of questions that appeared to shoulder compliance teams with the responsibility for ensuring the safe use of AI tools by their firms.
The Department of Justice’s Evaluation of Corporate Compliance Programs has made the importance of artificial intelligence governance frameworks clear, but it didn’t say what role compliance should play. Here’s the answer.
The U.S. Department of the Treasury’s Financial Crimes Enforcement Network issued an alert to financial institutions about their obligations to report deepfakes, warning artificial intelligence has given bad actors additional tools in their arsenal.
