If your company compliance program is not robust, brace yourself. The DOJ will make it pay up in more ways than one. For TD Bank the cost included a $1.8 billion penalty, an asset cap, independent monitoring, and even clawbacks of executive pay. The imminent change in DOJ’s regime might shift certain Department priorities, but compliance programs that fail to detect money laundering or fraud likely will continue to bring disastrous results for companies, particularly those in the financial sector. As I examine in my latest blog, TD Bank’s story serves as a wake-up call for companies, compliance officers, and corporate legal teams. I hope you enjoy.
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Robert J. Anello is a Principal at Morvillo Abramowitz Grand Iason & Anello PC, a well-known litigation firm located in New York City. You may contact him at ranello@maglaw.com.