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Sleaze in the Cinema: The Wolf at the compliance officer’s door

It’s astonishingly good news that after forty years of trial and error to develop the compliance profession, the law finally evolved to require both a new business “culture” and the compliance officer position to make this “culture” happen.  We should be the first to remind others and ourselves that this work is an historic opportunity. On the other hand, the challenges to “culture building” are present both inside and outside our companies.

One such external challenge is embodied in the popular new film, The Wolf of Wall Street. Despite the title, the film is not about the Wall Street bank melt down. It’s based on a memoir by the hustler himself, Jordan Belfort– a con-man’s perspective.

The Wolf recruits the little guys who dream of getting rich. He teaches them to manipulate clients who have the same dreams. A business publication exposes him, but this only brings in more recruits eager to learn his tricks.

In the end, Belfort escapes serious prison time, keeps his millions, and has this film made about himself. Not a bad life.

In this scenario, ordinary folks who follow the rules, do good work, and resist temptation are dull saps.  And we never see the suffering of the victims. In other words, The Wolf of Wall Street is a sly, cynical film, which a top film critic has called a “fake” based on a scam. It demeans the public norms that support an ethical business culture.

There are good movies – Margin Call is one — that explain the Wall Street meltdown and reinforce compliance goals. But for compliance officers, Wolf represents a significant “external” threat to building an ethical business culture.


Michael Scher is a contributing editor of the FCPA Blog. He has over three decades of experience as a senior compliance officer and attorney for international transactions. He is affiliated with ethiXbase, the owner of the FCPA Blog. He can be contacted here.

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  1. It's highly unlikely that a film showing the job of a compliance officer in a good light would ever be made as it's not considered an "exciting" profession, you can get a far more gripping storyline from staying on the wrong side of the law.

  2. "In the end, Belfort escapes serious prison time, keeps his millions, and has this film made about himself. Not a bad life."

    Based on what I have read about Belfort he pretty much lost it all when he went to prison.

  3. Hi Peter I – Thanks for your comment. The film is told from the Wolf's glorifying perspective. I thought it left it unclear what happened to the millions in the Swiss account. It would have been easy enough in the film to show him as penniless but the film version shows him sort of carefree and untroubled by lack of funds. It might not be in real life, but in the film the Wolf comes out well, leaving an ethically troubling message about whether defrauding people is good business.
    Thanks again for engaging with the post.

  4. To David's comment about the un-glorious lives of COs that won't be Hollywood movies: Yes it would be a challenge but not impossible. Maybe a combination of several films might work: Margin Call, The Whistleblower, Watergate-related films, a touch of Superman and Batman, and a dash of Dicken's Scrooge.
    We can do this! It's part of advocacy in 2014. Calling all scriptwriter-friends of the compliance profession.

    But who would play the CO: handsome/beautiful, super brave, romantic but tough as nails, loved and loving, loyal, filled with integrity ( add your own adjectives)?!

    Thanks for laying down the challenge for 2014.

    Michael Scher

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