If you are in a leadership position now, consider whether you may be falling into the trap that has caught so many others by taking liberties with the rules that you would not tolerate in your subordinates.

There may be occasions in which compliance with the law is not the highest ethical priority.

If we all tend to become jerks when we assume leadership positions, what can we do about it?

If such a massive scandal can happen at Wells Fargo in a tight regulatory environment, it can happen anywhere. The automotive repair industry and important discoveries in social psychology, however, point the way to some answers.

In the interest of justice and fair play, and in keeping with the Christmas spirit, I offer this defense of Scrooge and explore the question of whether such “an excellent man of business,” is truly an “ethical” man of business.

By generating these metrics, the ECI focuses its attention on what matters most — the key social dynamics in organizations that drive behavior. These are far more important than policies, procedures, or internal controls. There are written rules and then there are the real, cultural rules embedded in the organization that everyone follows.

For over 25 years, the in-house community has modeled corporate compliance programs on Federal Sentencing Guildines (FSG) — which outline seven elements for effective ethics and compliance. There have been, and will continue to be, many advantages to operating under these guidelines.

If you really want to get serious about better managing these risks, find a way to work with your leadership to implement a systematic approach to measure the effectiveness of the systems you and your organization are counting on to stay out of trouble.

When creating your investigation plan, what should your next steps be?

However, there was a fundamental weakness [in our financial controls] that we had failed to account for — the tendency of even the best financial professionals to follow what their boss tells them to do, regardless of whether it contradicts the rules.

Like pilots, corporate counsel and the management teams they serve are just as prone to the myopic preoccupation with fixing things that have gone wrong.

You don’t have to be a CEO to be a purpose-driven leader that looks beyond the bottom line to inspire the best in others. Every company leader — including those of us in the legal profession — can do this by making the effort to expressly identify the good that will come to others by a job well done.

When we tighten controls to the point that employees are compelled to obtain multiple levels of approval to get anything of consequence done, several things happen — and they’re all bad.

Too often, with the best of intentions, we strive to put so many controls on our company’s business activities that we either constipate routine, lawful business activities, or halt them all together.

In his TED Talk, Ariely begins by challenging the widely accepted notion that people are primarily motivated to behave the way they do by a desire for pleasure, money or power by making an observation about mountain climbers.

If you were asked to do so, how would you go about quantifying your company’s compliance and ethics risk tolerance in terms that would provide actionable intelligence to your leadership team?

Take a step back and examine whether you are, intentionally or not, “blinding” both yourself and your neighbors. In so doing, strive to run your business “consciously” by considering commercially reasonable options to improve everyone’s “vision” both for their benefit and your own.

If we are really interested in building and sustaining strong ethical cultures, how can we completely ignore questions relating to the basic ethical obligation our companies have to pay a fair wage?

The problem with this understandable response to a compliance crisis is that corporations with overblown compliance programs may end up becoming less able to manage their legal and ethical risks.

I think it is vital to look for opportunities both large and small to change or alter habits and to strive to achieve a greater capacity for self-regulation in the face of life’s challenges with the object of realizing our potential as authentic, ethical leaders.

Regardless of what steps you take to reduce your firm’s corruption risks, resist the temptation to engage in an orgy of demonstrating how terrible an enforcement action might be and, instead, pursue practical strategies to work with your colleagues to reduce your corruption risks.

To what degree is your identity connected with the five attributes of a strong ethical leader? These are: knowing, wanting, choosing, habituating and securing the “good.”

What universal principle or principles define the difference between good and evil? What yardstick might we use to measure the goodness or badness of any particular act?

Your fate and your company’s fate depend on whether you and your colleagues have adopted and mastered a practical approach to navigate a complex moral minefield where one misstep can end a brilliant career. Moreover, firms that successfully integrate moral considerations into their decision-making processes lower their enterprise risks and optimize business performance over the long term.

Perhaps we should not be surprised that the latest banking scandal to come to light involves manipulation of the global foreign exchange markets where an astonishing $5.3 trillion is traded daily.