It's astonishingly good news that after forty years of trial and error to develop the compliance profession, the law finally evolved to require both a new business “culture” and the compliance officer position to make this “culture” happen. We should be the first to remind others and ourselves that this work is an historic opportunity. On the other hand, the challenges to “culture building” are present both inside and outside our companies.
One such external challenge is embodied in the popular new film, The Wolf of Wall Street. Despite the title, the film is not about the Wall Street bank melt down. It’s based on a memoir by the hustler himself, Jordan Belfort-- a con-man’s perspective.
The Wolf recruits the little guys who dream of getting rich. He teaches them to manipulate clients who have the same dreams. A business publication exposes him, but this only brings in more recruits eager to learn his tricks.
In the end, Belfort escapes serious prison time, keeps his millions, and has this film made about himself. Not a bad life.
In this scenario, ordinary folks who follow the rules, do good work, and resist temptation are dull saps. And we never see the suffering of the victims. In other words, The Wolf of Wall Street is a sly, cynical film, which a top film critic has called a “fake” based on a scam. It demeans the public norms that support an ethical business culture.
There are good movies – Margin Call is one -- that explain the Wall Street meltdown and reinforce compliance goals. But for compliance officers, Wolf represents a significant "external" threat to building an ethical business culture.
Michael Scher is a contributing editor of the FCPA Blog. He has over three decades of experience as a senior compliance officer and attorney for international transactions. He is affiliated with ethiXbase, the owner of the FCPA Blog. He can be contacted here.