Fcpa Compliance Report

In the Department of Justice’s Evaluation of Corporate Compliance Programs, Prong 8 Incentive and Disciplinary Measures it states: Incentive System –How has the company considered the potential negative compliance implications of its incentives and rewards?  This week I have been considering how a company could use incentives to further a compliance program and the role of HR in this process. I want to consider how incentives might lead to the converse but looking at the intersection of sales incentives and compliance which led to the problems at Wells Fargo. When you misalignment these two concepts with a faulty sales strategy it can lead to a catastrophic failure, literally costing a company millions of dollars in fines, loss of business and depreciation of shareholder value.  The sales incentives under which Wells Fargo came to such grief is simple and even benign, cross-selling of products. As noted by Rachel Louise Ensign, writing in a Wall Street Journal (WSJ) article entitled “Banks Simple Strategy Get