Compliance into the Weeds: The Dark Side of AI in Employee Training
What to Do When Leadership Doesn’t Take Compliance Seriously
Compliance Tip of the Day - The ROI of Compliance
Moving Beyond the Usual Helpline Data
Avoiding a Bored Board
Compliance Tip of the Day: Compliance Responses to Design Intelligence
Compliance Tip of the Day: Avoiding CCO Liability
#Risk New York Speaker Series: Exploring AI Risks in Compliance with Gwen Hassan
Everything Compliance: Episode 155, To Tesla and Beyond Edition
Great Women in Compliance: Culture. Data. Ethics with Hui Chen
Compliance Amidst a Global Consensus Breakdown
Great Women in Compliance – Compliance is the Floor, Ethics is the Ceiling with Ellen Hunt
Innovation in Compliance: Innovative Approaches to Compliance and Training with Catherine Choe
FCPA Compliance Report: Upping Your Game in Compliance
Compliance Tip of the Day: Empowering Middle Managers to Drive Compliance Transformation
Creativity and Compliance: From Compliance Enforcers to Trusted Advisors: The Path Forward
Compliance Tip of the Day: Middle Managers as the Eyes and Ears of Compliance
Great Women in Compliance: Exploring the Future of Compliance - Key Takeaways from Compliance Week 2025
Mistakes Lawyers Should Avoid When Moving into Compliance
Innovation in Compliance: Exploring the Fractional COO Model with La Tonya Roberts
One of the most talked about topics in asset management is the possibility of offering Mutual Fund and ETF Classes in the same Fund. It appears that Funds may obtain the Relief necessary to offer these Share Classes in the...more
The issue of chief compliance officer (CCO) liability has long been debated; it has become a grave concern for CCOs, CEOs, and other C-suite executives who put on “too many hats” within an organization and take on the firm’s...more
The Financial Industry Regulatory Authority (FINRA) Sanction Guidelines have been significantly revised, now giving FINRA discretion to impose considerably higher fines on mid- and large-size firms. The revisions, published...more
On June 30, 2022, the SEC filed a settled action against Hamilton Investment Counsel, LLC (the “Firm”) and its chief compliance officer (“HIC CCO”). Notably, the SEC charged the HIC CCO with willfully aiding and abetting the...more
Many compliance officers believe they have targets on their backs. Indeed, according to industry-wide surveys conducted by the National Society of Compliance Professional (NSCP), 72% of compliance professionals are concerned...more
About a month ago, the SEC announced a settlement in a modest little case that has, nevertheless, managed to garner a lot of attention. This is a result of the fact that one of the respondents was the CCO, i.e., the Chief...more
Last week, yet another US Department of Justice (DOJ) official reportedly stated new corporate settlements “most likely” will include a requirement that the company’s chief compliance officer (CCO), as well as the chief...more
On March 17, 2022, FINRA issued Regulatory Notice 22-10 (“Notice”), which reminds FINRA member firms and their associated persons of the scope of supervisory liability for Chief Compliance Officers (“CCO”). The Notice...more
Understand What’s Happening in the Financial Industry Regulatory World With Commentary and Updates From Bracewell’s Experienced FINRA Team - We are pleased to introduce the inaugural issue of Bracewell’s FINRA Facts and...more
As a fitting cap to a busy month, on March 30, the SEC Division of Examinations announced its 2022 Examination Priorities. These priorities are consistent with the recent activities of the SEC more generally, as exemplified...more
Guidance clarifies assessment of liability under Rule 3110, including designation as supervisor, application of reasonableness standard, and factors for and against charging compliance officials. On March 17, 2022, the...more
I attended the four-day SIFMA Compliance and Legal seminar last week, and there were a bunch of interesting soundbites from regulators that folks might find interesting. The challenge at these conferences is always...more
The lack of specific guidance regarding failure to supervise liability for chief compliance officers (“CCOs”) has been a controversial and opaque topic that both FINRA and the SEC have struggled with for well over a decade....more
FINRA recently published Regulatory Notice 22-10 reminding firms of the scope of Rule 3110 (Supervision) and the potential liability of Chief Compliance Officers for failure to reasonably discharge supervisory...more
On March 17, the Financial Industry Regulatory Authority (FINRA) issued a notice, clarifying when chief compliance officers (CCOs) will face liability as supervisors under FINRA Rule 3110. Under Rule 3110, member firms are...more
In this Issue. The Financial Industry Regulatory Authority (FINRA) issued a reminder about chief compliance officer (CCO) supervisory liability under FINRA Rule 3110 (Rule 3110); and the Consumer Financial Protection Bureau...more
On March 17, 2022, FINRA issued a notice to member firms about Rule 3110 as it pertains to the potential liability of Chief Compliance Officers (CCOs) for failure to discharge designated supervisory responsibilities. ...more
In the securities industry, regulators like to say that the compliance professionals are their “partners.” But every so often, those regulators charge one of their compliance partners with rule violations. The compliance...more
I am reluctant to wade into the issue of CCO liability because I gravitate toward a simplistic answer to a complex question – when does a CCO cross the line to warrant civil or even criminal prosecution? My simplistic...more
In recent years, the Securities and Exchange Commission (the “SEC”) has increasingly brought enforcement actions against chief compliance officers (“CCOs”) in their personal capacities. On June 2, 2021, the New York City Bar...more
Over the past 15 years, chief compliance officers (“CCOs”) for financial services firms have come under increased scrutiny as the Securities and Exchange Commission (“SEC”) and Financial Industry Regulatory Authority...more
For the past decade, anti-money laundering (“AML”) has been at the forefront of securities regulators’ priorities. Indeed, AML enforcement cases have resulted in some of the highest fines imposed by securities regulators,...more
When you think about it, puns are kind of like securities enforcement actions. They could make you groan; they could make you laugh (if the conduct is particularly goofy) (or if you don’t like the respondent); or they often...more
Many of us watched Friends when it was originally broadcast using our rabbit ear antennas or through basic cable. Others watched it on reruns. While, more recently, some of us (or our children) watched on Netflix or, even...more
Summaries of recent legislative and regulatory developments with respect to: •The SEC’s Examination Priorities for 2021- •The SEC’s Focus on Digital Asset Securities- •The SEC’s New Marketing Rule... ...more