Compliance & Ethics

As the year winds down, the Office of the Comptroller of the Currency (OCC) has delivered a reminder to the banking world that accountability is non-negotiable. December’s enforcement actions reveal a mix of systemic breakdowns and individual misdeeds, painting a picture of an industry still grappling with old challenges in governance and compliance. From small-town banks failing to shore up their operations to individuals exploiting the system for personal gain, the OCC’s latest round of penalties shows a firm resolve to ensure stability and integrity in the financial system.

The Department of Justice (DOJ) accused CVS Pharmacy Inc.—the nation’s largest pharmacy chain—of knowingly filling illegal prescriptions for controlled substances. The suit claims CVS violated both the Controlled Substances Act (CSA) and the False Claims Act (FCA), directly contributing to the opioid epidemic that has ravaged communities across the United States.

The French Financial Markets Authority (AMF) handed out €4.15 million in fines on December 11, 2024, targeting four companies and three individuals. At the center of the scandal were allegations of spreading false or misleading information and manipulating the share price of Auplata, a French mining firm, in a saga that reads like a cautionary tale of what not to do in finance.

The European Securities and Markets Authority (ESMA) has just released its Final Report, outlining key updates to bond market transparency rules under the MiFIR (Markets in Financial Instruments Regulation) Review. These changes, which cover bonds, structured finance products (SFPs), and emission allowances (EUAs), are all about improving transparency while ensuring fairness and protecting liquidity providers from undue risk.

Grubhub will pay $25 million to settle charges brought by the Federal Trade Commission (FTC) and the Illinois Attorney General, following claims of unfair practices that impacted diners, delivery drivers, and small businesses. The settlement addresses a series of deceptive actions by the food delivery giant, from hiding the true cost of delivery to making misleading claims about earnings for drivers.

The National Highway Traffic Safety Administration (NHTSA) has finalized a rule formalizing its whistleblower program. This rule, which fulfills a mandate from the Motor Vehicle Safety Whistleblower Act under the Fixing America’s Surface Transportation (FAST) Act, is designed to strengthen existing whistleblower protections and create a more transparent system for uncovering safety issues in the auto industry.

Becton, Dickinson and Company (BD), a New Jersey-based medical device manufacturer, has agreed to pay a $175 million civil penalty to the Securities and Exchange Commission (SEC). The settlement resolves allegations that BD misled investors about significant risks associated with its Alaris infusion pump, a product that once contributed about 10% of the company’s profits.