11/17/20: The failure of Goldman Sachs’ compliance program led to a head spinning $3.3 billion settlement with the US Department of Justice and Securities and Exchange Commission. Why did the company’s program fail so miserably and what, if anything, does their experience have to teach other companies?
A post by Asher Miller on The FCPA Blog offers five “… takeaways for compliance officers everywhere” from the Goldman Sachs case. The takeaways are practical, but the pleasure of the post is in statements like this one: “Like in poker, if you can’t spot the fool around the table, it’s probably you.”