“People in my position fear that in too many places and in too many quarters, a culture of minimalism has taken root. Ethical standards have been lowered to doing only what is required to avoid an enforcement action or a criminal charge, rather than focused affirmatively on doing the right thing, staying comfortably clear of the line, and earning a robust reputation for integrity and honesty. Minimizing probity to maximize profit is a sucker’s game, but it is played every day.
“This impulse is troubling to prosecutors and outrageous to a public that expects American companies to aspire to more than the bare minimum. It does not suffice for a leader to give pro forma admonitions to behave honestly. A requirement to attend training sessions in the minutiae of the regulatory structure constitutes the bare minimum. So does the mere existence of compliance programs fly-specked by a hundred lawyers.”
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