Dealbreaker: ‘Wells Fargo is having its soul investigated by actual nuns’
Friday, March 9, 2018 at 8:22AM
Thomas Fox in Dealbreaker, US Attorney's Manual, Wells Fargo

I wish I could write a headline as great as the above banner which appeared over a piece written by Thorton McErney in Dealbreaker.

It came in a story about the actions of a group of institutional shareholders in Wells Fargo, led by the Interfaith Center on Corporate Responsibility. The group, which included the Sisters of St. Francis of Philadelphia, wanted the bank to perform a root cause analysis about what led to or allowed the recent spate of scandals at the banking giant.

Bloomberg reported that Sister Nora Nash, who oversees retirement funds for Sisters of St. Francis of Philadelphia, said: “They were in a culture where they believed their vision and values have carried them for the past 30 years and were continuing to carry them. Obviously, there was tremendous risk in their culture, and we need to take a serious look at the code of ethics, accountability and really look at the needs of the customer and community."

The Financial Times reported that a representative of Wells Fargo said the bank would publish a standards report that would identify the “systemic cultural and ethical root causes of recent scandals.” Further, this root cause analysis would also “assess the impact of the bank’s malpractice on customers and would set out its plans to “instill a commitment to high ethical standards” among employees.”

Given the number of continued missteps the bank has made since it first announced the fraudulent accounts scandal, you might reasonably ask why it has never pursued a root cause analysis. After all, such a process is now baked into the best practices of a compliance program under the FCPA, after its inclusion in the U.S. Attorney’s Manual with the introduction of the new FCPA Corporate Enforcement Policy.

Perhaps the final word should come from McEnery, he (or perhaps his editor) of the fabulous headline, who ended his piece with, “If Tim Sloan thought that Elizabeth Warren was a dogmatically intractable pain in the ass, wait until he ends up face-to-face with an actual nun peering at him from under her habit and musing 'Evil can be done by simply doing nothing, Timothy.' Mmm, that’s some good schadenfreude.”


Tom Fox is the Compliance Evangelist™. He leads the social media discussion on compliance with his award-winning blog, The FCPA Compliance and Ethics Blog and eight podcasts; The FCPA Compliance Report, Compliance into the Weeds, Everything Compliance, This Week in FCPA, 12 O’clock High-a Podcast on Business Leadership, Compliance Report-International Edition, Countdown to GDPR and Across the Board. 

He's the author of 12 books on compliance, ethics and leadership, including the international best-selling “Lessons Learned on Compliance and Ethics” and “Best Practices Under the FCPA and Bribery Act” and his series Fox on Compliance. His book "The Complete Compliance Handbook" will be published by Compliance Week in April 2018. It is available for PreSale by clicking here.

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