Firm Co-Founder Warren T. Allen II spoke with the Anti-Corruption Report regarding Deutsche Bank AG’s $130 million settlement stemming from alleged conspiracies to violate the Foreign Corrupt Practices Act (“FCPA”) and the Commodity Exchange Act. The settlement is Deutsche Bank’s second FCPA-related resolution within approximately sixteen months. The New York Department of Financial Services also separately fined the bank $150 million this past summer for alleged failures in its anti-money-laundering compliance program. Joining other commenters interviewed by the Anti-Corruption Report, Allen noted the importance of culture and incentives in preventing misconduct: “All the time and money companies spend designing controls, writing policies and auditing transactions is wasted if, at the end of the day, the only things that matter are revenue and profit. . . . Businesses should incentivize their personnel to protect the company’s reputation and look past short-term revenue.” Allen further added, “the certainty of rewards for revenue production provides powerful motivation to look the other way while, conversely, the relatively lower probability of detection in large organizations might not sufficiently dissuade misconduct.”
DC-Area Law Firm