Why Compliance Officers Need to Examine Sales

12/1/16: Tom Fox’ November 27 post on the FCPA Compliance and Ethics website (“Spikes in Sales and Compliance”) drills into the case of Wells Fargo to focus on a core compliance issue:  “Every Chief Compliance Officer (CCO) and compliance practitioner understands that the sales side of a business is where the highest risk is located because that is most generally the side of the business which generates the most money and potential profit.”  Yes, but here’s the upshot.  Fox writes that looking at sales numbers is “… not something which compliance professionals will generally have access to as a part of a compliance program.