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Adventures in Compliance

Adventures in Compliance: Episode III: The Priory School

Today, I consider the Adventure of the Priory School and the themes of criminality and compliance.

In the story The Adventure of the Priory School, Watson meets a character, Reuben Hayes, who  believes to be the most “self-evident villain” he has ever seen. The tale revolves around the disappearance of a Duke’s son who is kidnapped by the Duke’s illegitimate son, James Wilder, who has in turn hired that most evil person Hayes to kidnap the lad. In pulling off the crime, Hayes had killed the lad’s tutor, one Heidegger, who had gone off in search of the boy. Holmes resolves the matter, while Hayes swings for his crime, the illegitimate son, Wilder is packed off to Australia.
This story raises three key issues for a compliance program.

  1. Rarely to employees set out to engage in criminal activity so robust internal controls are imperative.
  2. Compliance practitioners need to study fraud examiners to understand the indicia of fraud and corruption.
  3. As compliance professionals also be objective and skeptical.