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Compliance Failures – Examples and Lessons
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.
- Common AML compliance failures
- Extraordinary AML compliance failures (intentional at the executive level)
- Widespread SOX failures (Sarbanes-Oxley Act) primarily control breakdowns leading to reconciliation breakdowns and incorrect reporting
- A broad failure of licensing controls where the company providing insurance products in the name of several major banks did not know which products were licensed is which states
For each case we will look at…
- What was the cause of the compliance failure
- How was a problem identified (red-flags, check list items, audit steps) and communicated internally (escalation process)
- What was done with regard to communication with regulatory authorities
- What did it take to investigate and address the failures
- What internal controls and risk mitigation steps were taken to prevent recurrence
Overview of the webinar
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.
Who should attend?
- Retail and Commercial Banking Leaders
- Mortgage Leaders
- Insurance Leaders
- Risk and Compliance Officers in Financial Services of any type
Why should you attend?
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.
Faculty - Mr.Jim George
Jim George is an independent consultant to banks focusing on issues of fraud. He brings over 25 years as a consultant to major banks in Associate Partner and Principal roles at PriceWaterhouse-Coopers Consulting, IBM Consulting in Bank Risk and Compliance and Andersen Consulting (now Accenture). He has also been SVP Operations for a Fortis-US division providing outsourcing services to the banking industry.
Jim's work has included projects in fraud investigation, fraud prevention, identity issues, compliance and AML (anti-money laundering). His background includes work in bank operations and payments strategy, reengineering, systems and quality improvement.