Top 10 Real-life Compliance Films

Posted by

Max Khamneian

on 22 Apr 2021

Top 10 Compliance Films

Many consider compliance a dry subject. But not according to Hollywood, who have often used it to dramatic effect in award-winning biographic films.

Here are our top 10 compliance films - a roll call of some of the best films with a compliance theme. Most importantly they are all inspired by real events. These salutary tales (well mostly) are a unique way to understand compliance.

They are not in any particular order, but each covers a key compliance area. And if you think we've missed your own favourite, let us know!

Learn about compliance from your armchair!

1. Compliance (2012)

Starring Dreama Walker, Ann Dowd

Based upon a strip search phone call scam that took place in Kentucky, where a caller posing as a police officer convinced a restaurant manager to carry out unlawful and intrusive procedures on an employee.

In the film, a fast-food worker is accused of theft and put through a demeaning ordeal as her boss, at the direction of a phone caller who says he's a policeman, subjects her to increasingly harsh forms of interrogation.

What can we learn?

  • Watch out for signs of fraudsters attempting to compromise or use a stolen identity. Callers who ask for their own personal details that they should have already, callers who request a significant transaction soon after changing their personal details, and callers who demand the return of a deposit or a rushed purchase without consideration of penalties and charges. 
  • Take extra care to prevent customer and colleague's information from being compromised. For example, be alert to phishing emails or unusual activity on your computer that suggests it may be infected by malware. 
  • Avoid giving out personal information eg date of birth or passwords even after a customer has passed a security questionnaire. 
  • Report any knowledge, suspicions or concerns you have about identity theft or fraud immediately to your manager or via our whistleblowing hotline. 

Free Identity Fraud Training Presentation

2. Bombshell (2019)

Starring Charlize Theron, Nicole Kidman and Margot Robbie

Bombshell is based upon the accounts employees trying to expose sexual harassment at Fox News.

Following Gretchen Carlson getting fired (ostensibly for supporting a weapons ban), she pursues a discrimination lawsuit against Roger Ailes (the then Fox CEO). After being defeated, Roger Ailes is fired by Rupert Murdoch. Ailes settles Carlson's lawsuit for $20 million and an apology from Fox, but with a gagging order.

Eventually, Fox paid sexual harassment victims a total of $50 million. In comparison, Ailes and another Fox employee Bill O'Reilly received $65 million in severance.

What can we learn?

  • Do everything possible to create a positive working environment where everyone is valued and treated with respect. 
  • Have grievance procedures in place to ensure that any incidents of sexual harassment are taken seriously and properly investigated. 
  • Make it clear in the company's Code of Conduct and policies that sexual harassment is unacceptable and will not be tolerated. 
  • Protect anyone who complains about sexual harassment from retaliation or victimisation. 
  • Review your corporate culture regularly to ensure that you don't condone behaviour that borders on sexual harassment, and prevent abuse by people in positions of power or authority. 
  • Offer different reporting mechanisms and empower people to speak out if they experience harassment or witness anyone else being subjected to it. 

Free Sexual Harassment Training Module

3. Philadelphia (1993)

Starring Tom Hanks and Denzel Washington

Philadelphia tells the story of Andrew Beckett, a lawyer at a large corporate law firm who is a homosexual and has developed AIDS.

When he is suddenly fired by the firm's partners, Beckett brings about a wrongful dismissal suit based on discrimination related to his sexuality and AIDS diagnosis

Philadelphia was one of the first mainstream Hollywood films to acknowledge HIV/AIDS, homosexuality and homophobia.

What can we learn?

  • Any decision to dismiss any employee should be based solely on merit and performance. No other criteria should be used to reach a decision. 
  • Some cases of dismissal are considered 'automatically unfair' regardless of reasonableness, such as dismissal due to pregnancy, trade union membershipor based on one of the nine protected characteristics. 
  • Keep in mind that all employees have the right not to be dismissed unfairly, and can make a complaint to an Employment Tribunal. 

Free Equality Training for Managers

4. The Wolf of Wall Street (2013)

Starring Leonardo Di Caprio, Margot Robbie and Jonah Hill 

Based on the life and times of Jordan Belfort, The Wolf of Wall Street depicts his rise from a junior Wall Street stockbroker to his eventual imprisonment.

In the 1990s, Belfort founded brokerage firm Stratton Oakmont and made a huge fortune defrauding wealthy investors out of millions, all while enjoying a hedonistic lifestyle. However, the SEC and the FBI eventually cotton onto Belfort's trading schemes and work to bring down his empire. 

Belfort ended up serving 22 months in prison after pleading guilty in 1999 to securities fraud and money laundering, as part of a scheme that cost investors approximately $200m.

What can we learn?

  • Act with integrity and honesty in all your professional dealings, and take extra care not to abuse your position and to manage any conflicts of interest. 
  • Watch out for the tell-tale signs of fraud. 
  • Don't become an unwitting accomplice to unscrupulous third parties, employees, customers, suppliers or others in acts of fraud. 
  • Review your anti-fraud systems and controls regularly to ensure that they are operating effectively and identify improvements. 
  • Report any knowledge or suspicions of fraud to the relevant authorities immediately. 
  • Don't make recommendations or induce others to deal while in possession of inside information. 

Free Fraud Prevention Good Practice Guide

5. Serpico (1973)

Starring Al Pacino, John Randolph and Jack Kehoe

Serpico is a biographical-crime film adapted from the book of the same name about Frank Serpico, an honest detective struggling to deal with corruption within the NYPD during his 11 years of service. 

Unlike the rest of the force, Serpico refuses to take bribes. This results in him being shunned by other officers and endangers his life. With his superiors turning a blind eye to department-wide misconduct, Serpico decides to blow the whistle on his colleagues' corruption. 

The actions of Frank Serpico resulted in the formation of the Knapp Commission, whom he testified before and resulted in criminal indictments against corrupt police officials. Nearly 50 years on, corruption still dogs the NYPD

What can we learn?

  • Don't offer or accept cash or anything of value in return for improper performance of any function. 
  • Comply with the expected standards for initial and ongoing due diligence of clients and third parties. 
  • Have a clear Gifts, Hospitality and Expenses Policy for guidance on what it is ok to offer and accept, and how any issues should be handled. 
  • Never make facilitation payments to secure or speed up the performance of a function by a government official. 
  • Be transparent and report any knowledge or suspicion of bribery immediately. 

Free Anti-Bribery Good Practice Guide

6. The Great Hack (2019)

Starring Carole Cadwalladr, David Carroll and Brittany Kaiser

This documentary takes a look at the 2015 Cambridge Analytica scandal. The UK-based political consulting firm began working on Ted Cruz's campaign to win the 2016 US Republican nomination. The firm had used Facebook as a means for 'political-voter surveillance' through the collection of user data points.

The illicit harvesting of personal data by Cambridge Analytica was first reported in December 2015 by Harry Davies. Independent investigations into data mining, along with whistle-blower accounts of the firm's impact on Brexit, led to a scandal over the influence of social media in political elections.

Facebook founder Mark Zuckerberg even had to testify before several committees of the United States Congress regarding data privacy. 

What can we learn?

  • Make sure that you protect personal data against unauthorised or unlawful processing, and accidental loss, destruction or damage. 
  • Don't conceal or cover up data losses or breaches. Report mistakes and violations promptly, so that damage to the data subject, your company and yourself can be limited. 
  • Don't start collecting personal data or using it for different purposes without first checking with your company's Data Protection Officer (DPO). 
  • Comply with procedures to ensure accuracy and observe the retention periods of personal data. 

Free GDPR Self Assessment Questionnaire

7. Erin Brockovich (2000)

Starring Julia Roberts, Albert Finney and Aaron Eckhart

Julia Roberts plays the titular character, a single mother who becomes a legal assistant. While looking at a case involving the Pacific Gas and Electric Company (PG&E), she discovers that they're poisoning a town's water supply with carcinogenic hexavalent chromium.

Despite having no legal, medical or scientific training, Brockovich succeeds in securing a $333m (£240m) settlement from PG&E for over 600 plaintiffs who alleged injury from drinking contaminated water.

Even today the US is going through something of a 'water crisis'. An investigation by The Guardian revealed that US tap water contained alarming levels of arsenic, lead and toxic chemicals.

What can we learn?

  • Do everything possible to get rid of any barriers to whistleblowing in order to increase reporting. 
  • Be aware of what drives and inhibits whistleblowers when making disclosures. 
  • Ensure that your policy focuses on equitable treatment. Never tolerate any detrimental treatment of whistleblowers, and make sure that those accused of wrongdoing by whistleblowers are also treated fairly. 
  • Make sure that the identity of whistleblowers is never disclosed. 

Free Whistleblowing Training Presentation

8. The Whistleblower (2010)

Starring Rachel Weisz, Monica Bellucci and Vanessa Redgrave

Inspired by the story of Kathryn Bolkovac, a police officer recruited as a United Nations peacekeeper for DynCorp International in post-war Bosnia and Herzegovina in 1999.

While serving there, she uncovered a sex trafficking ring serving and facilitated by DynCorp employees, with international peacekeepers turning a blind eye. Although she alerted the relevant authorities, Bolkovac was fired and forced out of the country. Eventually, she took the story to BBC News in the UK and won a wrongful dismissal lawsuit against DynCorp.

Modern slavery is a scourge that unfortunately still persists, with the ILO estimating there are 40 million people in forced labour

What can we learn?

  • Look out for signs of modern slavery and develop indicators of labour trafficking or exploitation. 
  • Always conduct due diligence on all clients, suppliers and third parties. Make sure that you 'know the chain'. 
  • Never confront anyone suspected of involvement in modern slavery. You may put potential victims at greater risk and valuable evidence may be lost. 
  • If you have concerns or see anything suspicious, report it immediately. People's lives may depend on it! 

Free Modern Slavery Awareness Poster

9. The Informant (2009)

Starring Matt Damon, Scott Bakula, Joel McHale

Mark Whiteacre is an executive at Archer Daniels Midland (ADM), who blows the whistle on his company's price-fixing to the FBI. ADM executives (including Whitacre himself) routinely met with competitors to fix the price of lysine, an additive used in the commercial livestock industry.

While Whiteacre tried to do a good deed by reporting his company's misconduct, in a bizarre twist of fate he ended up shining a light on his own criminality. It emerges during the FBI's investigation that while informing on his colleagues, Whiteacre was also embezzling money from ADM. 

Despite approaching the FBI to blow the whistle, Whiteacre ironically ended up spending 9 years in prison, getting a heftier sentence than his fellow executives (who only got 3 years). 

What can we learn?

  • Don't discuss or enter agreements with competitors. That includes prices, production volumes, intended bids or agreeing to share markets or customers. 
  • Don't place price, territorial or online sales restrictions on suppliers or distributors. If you need to do this, get advice from your legal team first. 
  • Be careful not to act in ways that restrict competition in any market. By exploiting your dominant position e.g. refusing to supply, prohibiting discounting, imposing exclusive obligations or entering 'pay-for-delay' deals. 
  • Never discuss commercially sensitive information. That includes future pricing plans and promotions, with competitors or suppliers, or RRPs with retailers. 
  • Report any suspicion of competition law violation immediately. This is vital, because under leniency rules, the first to report to the authorities can often escape prosecution. 

Free Competition Law Training Presentation

10. Rogue Trader

Starring Ewan McGregor and Anna Friel

Ewan McGregor takes the lead in the true story of Nick Leeson, a trader at Barings Bank. He hid huge losses whilst the powers-that-be back in London seemed asleep at the wheel. The £800 million losses he built up contributed to Barings going bankrupt. Leeson was sentenced to six and a half years in jail. 

What can we learn?

  • Ensure you have restrictions in place to control the trading of instruments. In terms of which desks can trade them, when they can trade them, and how much in a given period. 
  • Ensure trading limits are carefully set and monitored. To protect the company and to satisfy regulators. 
  • Never try to cover up any losses that you or your employees have made. Doing so may cause the problem to spiral out of control. 

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