Imagine that you are the chief compliance officer for an international stock brokerage firm. You are asked to meet with the board of directors of the firm to provide suggestions that will enable the firm to ensure that employees comply with the firm’s compliance programs:How will the standard articulated by the courts in Caremark and Citigroup inform your recommendations?
1. In the Citigroup litigation, shareholders alleged that directors breached their fiduciary duty by allowing the business divisions to remain active in the subprime mortgage market long after other competitors, such as JP Morgan, began to reduce their exposure to these types of loans and the exotic financial products that financial product engineers developed using […]