ABSTRACT

This chapter looks at how the role of compliance needs to change. The need for change was highlighted by the Wells Fargo debacle. The lack of input in financial services has been particularly evident with the debacle of Wells Fargo in the United States, Coop Bank in the United Kingdom and in the various banks that collapsed in the 2007–2009 financial crisis. Wells Fargo was very conscious of the need to protect its reputation. All managers may have been responsible for preserving the bank’s reputation but none of the senior management thought through their acts of commission or omission. There is some evidence that compliance reporting lines are moving away from heads of legal and chief operating officer to the CEO and chief risk officer. It is worth examining a recent example of the challenges faced by compliance, and other control functions, in relation to corporate strategy and management.