Getting Seriously Public About Non-Compliant Expenses

A dollar here.  A twenty there.  A couple of doctored receipts for dinner at the office.  What’s the big deal?  We’re not talking about a first class ticket and a suite at the Olympics or purchasing a Ferrari.  We’re talking about take-away dinners.  Yeah, sure it’s in violation of the company’s policy, but nobody reads that carefully anyway.  And nobody gets punished for that kind of little indiscretion, right? 

Wrong.  If the recent news is anything to go by, companies are getting serious (and going public) with enforcement of their gifts and expense policies, no matter how small the violation. 

Most fraud and anti-bribery enforcement actions which involve gifts and hospitality include lavish elements.  Reports of managers stealing from the company to take luxury trips, buy themselves luxury gifts, or throw themselves lavish parties is the stuff of many articles and court cases.  But the trend in companies is turning toward the punishment of smaller indiscretions, and the compliance profession should celebrate this shift. 

Wells Fargo

Just last week the Wall Street Journal published an article detailing the firing of more than a dozen employees who violated the meal reimbursement policy.  At Wells Fargo, employees were allowed to buy dinners and charge them to the firm after 6:30 p.m. if they were working late.  Some employees ordered meals before that time, then altered receipts for dinners charged to the bank.  Employees ranging in seniority from analysts to managing directors were punished for violating policy.  The concern was brought to the attention of the bank by “concerned team members.”