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
Two SEC enforcement actions from earlier this month, each including charges against a firm’s Chief Compliance Officer in their personal capacity, underscore the importance of maintaining accurate records and upholding...more
Responding to a “concern” from Chief Compliance Officers (CCOs) to the purported increase in enforcement actions holding compliance personnel personally liable, the New York City Bar Association recently released a framework...more
A long time ago, long before there existed any whistleblower statutes, I had a client – a CCO of a broker-dealer – who discovered some pretty funky trading at his firm. As he tells the story, when he went to see his boss (who...more
In a 30-day period, the U.S. Securities and Exchange Commission (“SEC”) has released guidance in three ways regarding certain views on the important role and potential liability risks of chief compliance officers (“CCOs”)....more
DISCUSSION OVERVIEW - - Duty to Establish a Compliance Program - Chief Compliance Officer (“CCO”) - Written Policies and Procedures - Annual Review Process - SEC Exams and Enforcement - Code of Ethics ...more
The Commodity Futures Trading Commission issued revised guidance for mandatory chief compliance officer annual compliance reports for futures commission merchants and swap dealers. However, the proposed recommendations are...more
On September 12, 2019, the Commodity Futures Trading Commission (CFTC) announced a settlement with Phillip Capital Inc. (PCI or the “Company”), a registered futures commission merchant (FCM), after hackers successfully...more
A recent settled SEC order, In re Arlington Capital Management, Inc. and Joseph F. LoPresti, highlights the potential benefits of voluntarily taking steps to remediate conduct or practices that could run afoul of the SEC’s...more
OCIE Highlights Frequent Topics for Compliance Deficiencies for Investment Advisers - On Feb. 7, 2017, the Securities and Exchange Commission’s (SEC’s) Office of Compliance Inspections and Examinations (“OCIE”) published...more
FINRA Bar Results from Assertion of Fifth Amendment Right against Self-Incrimination in Criminal Action - On October 5, 2016, the Financial Industry Regulatory Authority (“FINRA”) barred an indicted investment adviser,...more
The Securities and Exchange Commission (the SEC or the Commission) brought over 400 enforcement actions in the first half of 2016 and is on pace to surpass its record of 807 enforcements actions in a single fiscal year, which...more
The SEC’s recent aggressive enforcement posture against chief compliance officers has raised many concerns, including whether the SEC’s actions are actually chilling robust compliance efforts. To protect themselves against...more
In remarks before the 2015 National Society of Compliance Professionals, National Conference, Andrew Ceresney, Director, SEC Division of Enforcement, outlined the type of criteria used to charge Chief Compliance Officers with...more
Non-Enforcement - SEC Decides Against Mounting an Appeal in Koch Ruling - The July 2015 ruling by the D.C. Circuit Court in Koch v. SEC will apparently not be challenged by the SEC. The Court ruled in that...more
According to the SEC’s most recent financial report, as of August 2014, SEC-registered investment advisers managed $62.3 trillion in assets. Not surprisingly, investment advisers attract a great deal of attention from the...more
Securities and Exchange Commission members Daniel M. Gallagher and Luis A. Aguilar will soon leave the SEC, but neither is keeping quiet about the SEC’s treatment of chief compliance officers (CCOs). Gallagher recently...more
Non-Enforcement - Form PF — What Purpose? SEC registered investment advisers with at least $150 million of assets under management in private funds are required to periodically file Form PF with the SEC. The...more
The SEC recently settled an enforcement action against an investment advisor, Parallax Investments LLC, its owner and its Chief Compliance Officer, finding that metadata in the CCO’s annual compliance memorandum contradicted...more
In mid-June, SEC Commissioner Gallagher issued a strongly-worded public dissent from two enforcement actions against investment-adviser CCOs, accusing the Commission of “cutting off its nose to spite its face” by punishing...more
SEC Commissioner Daniel Gallagher, in a speech on June 25, 2015, said that a perceived trend by the SEC toward “strict liability” for chief compliance officers (CCOs) is “sending a troubling message.” The statement...more
In a strongly-worded public statement last week, SEC Commissioner Gallagher chided the Commission for “cutting off the noses of CCO’s to spite its face.” Explaining his dissent in two recent enforcement actions imposing...more
Investment Adviser Chief Compliance Officer Blamed in SEC Lawsuit for President’s Theft of Client Funds; SEC Commissioner Criticizes Enforcement Actions Against CCOs Generally - The Securities and Exchange Commission...more
SEC Commissioner Daniel Gallagher published a statement explaining his dissent in two recent enforcement actions in which the Chief Compliance Officer of an investment adviser was charged, noting that the trend in such...more
In This Issue: - SEC Proposes Changes to Reporting and Disclosure Obligations for Investment Companies and Advisers - SEC Charges Hedge Fund Executives and External Auditor for Improper Disclosure of Expense...more
The Commission failed to prove its insider trading claims to the satisfaction of a jury for the second week in a row. This time a Los Angeles jury rejected claims of the agency against a corporate executive that were tied to...more