Two recent SEC enforcement actions serve as a sharp reminder that Chief Compliance Officers (CCOs) can face personal liability for what they do – or fail to do – in the course of regulatory examinations for registered...more
8/15/2025
/ Chief Compliance Officers ,
Compliance Management Systems ,
Corporate Counsel ,
Enforcement Actions ,
Investment Advisers Act of 1940 ,
Personal Liability ,
Policies and Procedures ,
Recordkeeping Requirements ,
Regulatory Requirements ,
Securities and Exchange Commission (SEC) ,
Securities Regulation
Three recent developments in relation to ESG related disclosures are of note: (1) on March 10th, the US Department of Labor announced it would not enforce its own rules related to ESG investing, (2) on the same day the EU’s...more
3/16/2021
/ Climate Change ,
Corporate Counsel ,
Corporate Governance ,
Corporate Misconduct ,
Department of Labor (DOL) ,
Disclosure Requirements ,
Environmental Social & Governance (ESG) ,
EU ,
Investment ,
Regulatory Reform ,
Securities and Exchange Commission (SEC) ,
SFDR
The Securities and Exchange Commission (“Commission” or “SEC”) recently instituted settled administrative and cease-and-desist proceedings against a chief compliance officer of a registered investment adviser for record...more