In the world of governance, risk, and compliance (GRC), there’s no shortage of incidents that illustrate what can happen when companies fall short of their compliance responsibilities.
In this blog, we’ll present the “best of the worst” compliance failures—a collection of incidents and stories that serve as stark reminders of the high stakes involved in maintaining rigorous GRC standards.
These eye-opening GRC challenges often stem from a combination of factors:
- inadequate internal controls
- complacency towards evolving regulations
- misguided prioritization of short-term gains over long-term compliance sustainability.
They underscore the critical need for robust GRC frameworks that proactively address risks, anticipate regulatory changes, and foster a culture of compliance from the top down.
Boeing: Turbulence in Compliance
Background: Boeing’s troubled journey with the 737 Max aircraft is a textbook example of how lapses in compliance can lead to catastrophic outcomes. Following two fatal crashes in 2018 and 2019, investigations uncovered significant issues in the aircraft’s design and certification process. The company faced intense scrutiny over its compliance with safety regulations. This resulted in a global grounding of the 737 Max fleet.
Analysis: The crashes exposed systemic problems within Boeing’s safety culture and regulatory oversight. The company’s failure to disclose critical information about the aircraft’s Maneuvering Characteristics Augmentation System (MCAS) to pilots and regulators was a key factor in both accidents. Boeing’s compliance shortcomings led to the tragic loss of life and severely damaged the company’s reputation and financial standing.
Boeing’s internal culture was scrutinized. Reports indicated immense pressure to meet production deadlines, which, understandably, compromised safety standards. Internal communications showed that employees had reservations about the MCAS system but felt these concerns were not adequately addressed due to the push to “rush to market.”
The company now faces billions of dollars in fines, settlements, and lost revenue, not to mention the long road to regaining public and regulatory trust.
This case highlights the critical need for robust compliance frameworks and proactive GRC strategy. It also emphasizes fostering a corporate culture where safety and compliance are prioritized over speed and cost savings.
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Citigroup: The $900 Million Oops
Background: In 2020, Citigroup made headlines for accidentally wiring $900 million to a group of lenders—a mistake initially attributed to a “clerical error.” The incident was a stark reminder of the critical importance of robust internal controls and compliance mechanisms within financial institutions.
Analysis: Citigroup’s error highlighted significant operational risk management and internal weaknesses. The bank’s outdated software and inadequate training contributed to the mistake, showcasing the need for continuous improvement in GRC processes. This incident prompted an internal audit and led to a comprehensive overhaul of Citigroup’s payment systems and procedures.
Moreover, the incident revealed a need for proper communication and coordination among different departments within the bank. It also exposed the vulnerabilities in legacy financial systems that many banks still rely on, stressing the need for modernization.
The costly blunder led to lawsuits and regulatory penalties. The incident is a cautionary tale for financial institutions about the potential economic and reputational risks of failing to maintain robust controls. It also underscores the necessity for continuous monitoring and updating of internal systems to prevent similar occurrences. The situation prompted Citigroup to upgrade its technology and reassess its training programs and inter-departmental coordination mechanisms.
Silicon Valley Bank: A Case of Unchecked Risks
Background: Silicon Valley Bank, a major player in the fin-tech startup ecosystem, collapsed suddenly in March 2023. The bank’s failure was attributed to a combination of balance sheet risks, a liquidity crunch, and gaps in regulatory oversight.
Analysis: SVB collapsed primarily due to a significant duration mismatch on its balance sheet, where short-term liabilities funded long-term assets. This made the bank extremely vulnerable to interest rate hikes. As venture capital funding dried up, SVB’s tech startup depositors began withdrawing funds en masse, leading to a liquidity crisis. The bank was forced to sell assets at a loss to meet these withdrawal demands.
The regulatory oversight failed to anticipate the speed and scale of these withdrawals, highlighting the need for dynamic risk management practices that can adapt to rapidly changing financial conditions. SVB’s downfall illustrates the necessity of comprehensive risk management strategies that consider both market and liquidity risks.
SVB’s failure underscores the importance of maintaining a robust compliance framework that includes regular stress testing and scenario analysis to identify potential vulnerabilities. This incident serves as a cautionary tale for financial institutions to prioritize long-term stability over short-term gains and ensure regulatory requirements are met.
Credit Suisse: A Legacy of Compliance Failures
Background: Credit Suisse faced a near-collapse in March 2023, leading to its takeover by UBS. The bank’s downfall resulted from several high-profile compliance failures and risky business practices.
Analysis: Credit Suisse’s troubles were rooted in significant compliance lapses, including its involvement in the Archegos Capital Management collapse and the Greensill Capital scandal. In 2021, Credit Suisse suffered massive losses due to its exposure to Archegos, a family office that defaulted on margin calls, revealing inadequate monitoring and control mechanisms within the bank. Credit Suisse’s heavy involvement with Greensill Capital, which collapsed in 2021, also led to substantial financial losses and legal challenges.
The repeated compliance failures eroded trust among clients and investors, severely impacting the bank’s financial stability. Credit Suisse’s experience highlights the importance of maintaining robust compliance systems and strong corporate governance frameworks to prevent financial misconduct and manage risks effectively.
The near-collapse of Credit Suisse underscores the need for financial institutions to embed compliance deeply within their organizational culture. Ensuring that risk management is not just a checkbox exercise but a core part of business operations is vital for long-term sustainability. The bank’s downfall also illustrates the broader systemic risks of compliance failures and the critical role of effective GRC applications in maintaining financial stability.
T-Mobile: Data Breach Debacle
Background: In 2021, T-Mobile suffered a major data breach that exposed the personal information of over 50 million customers. The breach was one of several recent cybersecurity incidents that have plagued the company, raising serious questions about its data protection and compliance practices.
Analysis: The breach revealed significant shortcomings in T-Mobile’s cybersecurity defenses and compliance with data protection regulations. The company’s repeated failures to safeguard customer data have resulted in substantial financial penalties and reputational damage. T-Mobile has since enhanced its cybersecurity posture, investing in advanced security technologies and improving its incident response protocols.
Additionally, the breach exposed the need for better third-party risk management. Reports indicated that the vulnerability exploited in the breach was tied to a third-party service provider, highlighting the importance of assessing and mitigating risks associated with external partners.
T-Mobile’s experience underscores the critical importance of robust cybersecurity and data protection measures. In an era where data breaches are increasingly common, companies must prioritize compliance with data protection regulations to protect their customers and avoid severe penalties. This case is a stark reminder of the ongoing battle between corporations and cybercriminals and the need for constant vigilance.
Meta’s ‘Pay or Consent’ Model: A Potential Case in Point
Background: In July 2024, the European Commission issued its preliminary findings on Meta’s controversial “pay or consent” model on Facebook and Instagram. This model forces users to either consent to data tracking for personalized ads or pay a subscription fee to avoid it. The Commission argued that this model violates the EU’s Digital Markets Act (DMA), designed to promote fair competition and protect user rights.
Analysis: The investigation highlighted that Meta’s approach restricts user choice and does not offer a genuinely free, less personalized alternative. The DMA’s strict guidelines reflect the EU’s dedication to limiting the power of digital giants and ensuring consumers can make meaningful decisions regarding their data.
The case highlighted the broader issue of how tech giants leverage user data for commercial gain. The model employed by Meta was seen as an attempt to circumvent stricter data protection laws by monetizing user consent, which raised ethical and legal questions.
Although the findings are not final, Meta could face severe repercussions. If the model is non-compliant, Meta may face fines up to 10% of its global annual turnover, potentially amounting to billions of dollars. Repeated violations could result in even steeper penalties. This situation is a critical warning for other tech firms about meeting regulatory standards.
Summing it Up
By learning from the past and continuously evolving, businesses can turn compliance challenges into opportunities for improvement and innovation. The stakes are high, but you can achieve excellence in governance, risk, and compliance with the right strategies and tools.
At Centraleyes, we’re dedicated to providing the tools and insights needed to navigate the complex GRC landscape confidently and successfully.
Start Getting Value With
Centraleyes for Free
See for yourself how the Centraleyes platform exceeds anything an old GRC
system does and eliminates the need for manual processes and spreadsheets
to give you immediate value and run a full risk assessment in less than 30 days