Lesson 14. The Possibility of Being Too Ethical

In 2014, former FBI Director James B. Comey gave the keynote speech at our Compliance & Ethics Institute in Chicago. When introducing him, I said that I believed the FBI had one of the best compliance programs of any government agency. Comey thought so too, stating that the FBI was very proud of their compliance program.

Comey went on to speak about cybersecurity, and how to deal with cyber threats. He said that these threats don’t always come from outside a company, they often come from inside—contractors, employees, system administrators―people with a grudge or some problem with someone or something in the company. Comey also spoke about the importance of building a culture where people care about one another and the security of the company. If this kind of culture exists, then employees feel safe sharing anything they notice that could harm the business.

That was the second time I had met Comey. On both occasions he was very impressive. However, shortly after this presentation, all heck broke loose at the FBI. Here’s a little recap of what happened, and how Comey broke with FBI policy in 2016 in regard to the investigation of Hillary Clinton’s use of private servers and email system for government work while secretary of state.

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