Professional Diligence and Integrity: Lessons from the Wells Fargo Case for Risk Managers and Internal Auditors

 

The recent decision by the Office of the Comptroller of the Currency (OCC) against former Wells Fargo executives underscores the importance of professional diligence and integrity in risk management and internal auditing. This case highlights how failures in monitoring improper practices can lead to severe penalties, impacting both the company and its executives.

The OCC investigation revealed that Claudia Anderson, who served as the Community Bank Group Risk Officer, failed to adequately challenge the bank’s incentive program, neglected to implement effective controls to mitigate the risks of improper sales practices, and did not escalate known risks. Additionally, she was found to have provided false or misleading information to regulators during 2015 examinations. Former internal auditors David Julian, Chief Auditor, and Paul McLinko, Executive Audit Director, also failed to design effective audits to detect and document irregularities and did not properly escalate issues. In McLinko’s case, there was an additional concern regarding his compromised professional independence due to his close relationship with the bank’s retail division.

To prevent such scenarios, risk managers and internal auditors must operate with technical rigor, independence, and integrity, ensuring that internal controls are effective, and that risk oversight and escalation mechanisms function appropriately. Professionals in these areas need the courage to challenge policies and practices that could compromise governance and expose the organization to financial, regulatory, and reputational risks. Furthermore, it is crucial that they are embedded in a corporate culture that prioritizes transparency and compliance, thereby reducing their own exposure to potential penalties.

The Wells Fargo case serves as a critical warning: governance failures and oversight negligence can lead to severe legal and reputational consequences. For professionals in risk management and internal auditing, the lesson is clear— 
complacency and negligence are not options. A proactive and vigilant stance, grounded in best governance practices, is essential to ensuring that business decisions are made with ethics and responsibility.

Questions for Reflection:

1. How can corporate governance strengthen the independence and effectiveness of risk managers and internal auditors?
2. In what ways can companies foster a culture of transparency and compliance to mitigate fraud and irregularities?
3. What challenges do audit and risk professionals face when attempting to escalate critical issues within an organization?
4. How can companies ensure that incentive programs do not pose risks to organizational integrity?
5. What steps can professionals take to develop a more critical and proactive approach to risk identification and mitigation?

In future articles, I will explore these questions in greater depth. For now, I leave you with this thought:

Are you comfortable with how you are currently managing risks or conducting audits? Do you feel supported in questioning company practices that could pose governance, integrity, or reputational risks?

Be Happy!

The Importance of knowing How to Use Performance and Risk Indicators

By Eduardo Pardini

The success of an organization is not a matter of chance; it results from a well-structured set of practices that ensures its sustainability and growth over time. Among these practices, effective corporate risk management stands out as a critical component. However, for this management to be truly efficient, it is essential to have a monitoring system based on well-defined indicators.

Although much has been said about the importance of KPIs (Key Performance Indicators) and KRIs (Key Risk Indicators), significant doubts remain about when and how to use them effectively. This confusion is understandable, as both types of indicators have different yet complementary purposes:

• KPIs: Performance indicators that measure progress toward the organization's operational or strategic objectives. These measure the past, the results achieved, or risks that have already materialized. They are reactive, as management acts based on them to redirect activities and/or address the measured risk factor.
• Example: The sales conversion rate is a KPI used to measure the efficiency of a sales team in turning opportunities into actual clients.
• Another Example: The percentage of interest paid due to late payments to suppliers compared to the estimated residual risk and/or the acceptable risk level defined by the organization's risk appetite.
  
• KRIs: Risk indicators that provide early warnings of potential threats that could adversely impact the achievement of objectives. These are proactive indicators, anticipating future risks before they materialize.
• Example: An increase in household debt is a KRI indicating a potential risk of reduced planned sales levels.
• Another Example: Possible pressure on production costs due to a drought in the commodity-producing region, impacting the final product price.

Clearly distinguishing when and how to use these tools is crucial for ensuring that the organization has a holistic view of both its performance and the risks it faces.

The Strategic Role of Indicators

Simply implementing indicators is not enough; they need to be strategically selected and monitored. This means that each indicator must align with the organization's operational reality and strategic planning. Intelligent use of these tools is what differentiates prepared and insightful organizations from those caught off guard by unexpected risks or unattainable goals.

By monitoring KPIs, an organization can assess whether its goals are being achieved and identify opportunities for improvement. On the other hand, KRIs help anticipate and mitigate threats before they materialize, safeguarding the results already achieved.

Sustainable and Lasting Success

When properly applied, the combination of KPIs and KRIs is not merely a recommended practice; it is an indispensable condition for ensuring the sustainable success and longevity of an organization. These indicators enable companies not only to monitor their operations but also to act proactively in response to risks and opportunities.

Thus, by adopting an indicator-based approach, organizations strengthen their capacity for anticipation, enhance their resilience, and achieve consistent results over time.

Final Reflection

I invite you to reflect: Is your organization using KPIs and KRIs in an integrated and strategic manner? If not, it might be time to reassess your monitoring processes and tools. After all, the future belongs to companies that know where they are and where they are going—without losing sight of the risks along the way.