Compliance
Written by Asbjorn Osland and Denis Collins
Case Summary
The case deals with a major international bank that has been mired in corruption. Although not
Case Analysis
The application to ethics is direct in terms of corruption. But the case goes beyond ethics in that
it focuses on how to bring about compliance.
Critical Thinking Questions and Suggested Answers
1. DB appeared to have a culture of corruption. How should executives change it?
In operational terms, what could DB do to change the culture to enhance its
viability as a going concern?
It had done the appropriate things in terms of training, focusing on corruption, and so
2. How could DB use its business relationship with the Trump brand to its
advantage without violating the emoluments clause of the Constitution and
raising the ire of politicians opposed to Trump?
Trump could
3. Should the German government bailout DB in the event it fails? Is it too big to
fail (i.e., too important to the German economy)?
A systemic failure involving DB and other European banks could be problematic. As
4. Check on DB’s current share price. Has it gone up or down of late? How do the
analysts explain its performance?
The standard practice for case analyses is for students to limit themselves to
information in the case. However, given the proclivity of students to access the
5. Has DB been fined or found guilty of corruption since early 2017 when it paid the
$7.2 billion fine? What accounts for its actions, according to the reputable
business press (e.g., Wall Street Journal, Financial Times, New York Times)?