by Jonny Frank, Michele Edwards, and Chris Hoyle
Left to right: Jonny Frank, Michele Edwards, and Chris Hoyle (photos courtesy of StoneTurn, LLP)
It is tempting for organizations to downplay compliance violations as an isolated event attributable to a few bad apples. However, experience teaches that misconduct is often worse than initially thought. Wrongdoers who confess rarely admit to their complete wrongdoing. And it is common for the same or similar misconduct to occur across business lines and geographies.
Because wrongdoing is often much more extensive than originally believed, organizations cannot afford to assume that an incident is an isolated event. Imagine the legal implications—and embarrassment—if the government, public or other stakeholders discover that an organization’s internal investigation failed to detect the full extent of the perpetrators’ wrongdoing or similar schemes committed by others in the organization. There may also be more extensive financial losses to recover that the organization needs to be aware of.
