Page 315 - Bank Case Studies

“Ethical programs “must be linked to material

incentives in order to be effective,” he wrote. Any

deviation from the ethics program, “even if

financially lucrative, must be punishable by

nonpayment or clawback of bonuses,” he said,

adding, “Sharp practice that complies with the law

but causes reputational damage should be

penalized.” (1)

The cycle of corruption is based on three elements

money, power and policy. The banks were not immune
from this cycle particularly if there were few effective

checks in place to limit the cycle’s impact.

Punitive action in the form of fines are ineffective. Wells

Fargo’s $185 million fine when set against its quarterly