General Fact Pattern

You have been selected to serve as chief compliance officer (CCO) for Dollar Bill Enterprises, a global company based in the US, focused on financial services. As part of your first week on the job, you meet with a number of your direct reports and business people, and you learn about the following issues facing the company and new business opportunities that are on the horizon:

1. While there is a strong culture of compliance, employees consistently violate policies around gifts and entertainment. Specifically, salespeople often expense more than the allotted limits and there have been instances where they have entertained groups of people that included government officials
2. The Compliance team is grossly under-staffed and the technology being used the current staff is mostly ineffective and costly.
3. The Product Team wants to introduce crypto-currency as a form of payment, something DBE's competitors do not provide.

Fact Pattern

While reviewing your monthly exception reports (e.g., a report that displays individuals who have violated company rules) you realize one of the top employees, Jake Gatsbee, has had a 12 month streak of violating the gifts and entertainment rules. Specifically, the rules set forth parameters by which personnel can provide corporate gifts and entertainment (e.g., lunches/dinners, tickets to a baseball game using the company's box seats, etc.) in line with local regulations. However, in your first 30 days on the job, Gatsbee has violated the G&E rules 10 times. You ask Gatsbee's admin to provide you a list of attendees for the last event he hosted, a yacht cruise with 3-course dinner and wine, and included are several individuals who are on the enforcement board for the state regulator. When you probe your team on how this behavior could go unnoticed for so long, you quickly realize that Gatsbee's team did not think it was a big deal and some of your team was unaware of the policy.

Questions:

Provide a detailed response to the following related to the above:

• What steps are you taking regarding Gatsbee?
• What steps are you taking regarding Gatsbee's team
• What steps are you taking regarding your team