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Enforcement Actions Personal Liability Chief Compliance Officers

Proskauer Rose LLP

SEC Cites Falsified Compliance Records in Two Recent SEC Settlements with CCOs

Proskauer Rose LLP on

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

Society of Corporate Compliance and Ethics...

[Webinar] Navigating CCO Liability risks: Tips for staying out of the SEC’s Crosshairs - October 12th, 12:00 pm - 1:30 pm CT

Learning Objectives: - CCO liability can be a complex yet nebulous concept to navigate. Therefore, it’s important to understand how CCO liability is being defined by regulating bodies. - Mitigating the risks of CCO...more

Eversheds Sutherland (US) LLP

The Chief Compliance Officer Who Wasn’t Framed: Applying the NSCP’s Firm and CCO Liability Framework to an SEC CCO Enforcement...

On June 30, 2022 the Securities and Exchange Commission (SEC) brought a settled enforcement case against a Chief Compliance Officer (CCO) and a Registered Investment Adviser (RIA). At first glance, the case appears...more

Burr & Forman

FINRA Clarifies CCO Supervisory Liability

Burr & Forman on

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

BakerHostetler

SEC Commissioner Peirce Delivers a Speech on Defining the Parameters of CCO Liability

BakerHostetler on

The question of how to define the parameters of personal liability for compliance officers in the financial services industry has been around for several years. In a 2015 speech, then-SEC Enforcement Director Andrew Ceresney...more

NAVEX

New Report Stirs Old Fears of Compliance Officer Liability

NAVEX on

Everything old is new again eventually. So perhaps it should come as no surprise that compliance officer liability is back in the news. The New York City Bar Association recently released a report warning that compliance...more

WilmerHale

Foreign Corrupt Practices Act Alert - Global Anti-Bribery Year-in-Review: 2019 Developments and Predictions

WilmerHale on

Enforcement activity reached new heights in 2019. The year saw the two largest corporate resolutions in the history of the FCPA, corporate penalties paid to US enforcement agencies topped last year’s record levels, and...more

Eversheds Sutherland (US) LLP

Recent guidance brings OFAC in line with domestic and global compliance trends

On May 2, 2019, the US Department of the Treasury’s Office of Foreign Assets Control (OFAC) issued guidance titled “A Framework for OFAC Compliance Commitments” (Guidance), providing direction regarding what OFAC considers to...more

Foodman CPAs & Advisors

Are Compliance Officers at Financial Institutions Now in the Hot Seat for Fines?

Otherwise reputable Financial Institutions continue being sanctioned for regulatory non-compliance. Well known “household” names continue receiving fines for failing to establish and implement adequate Anti-Money Laundering...more

McGuireWoods LLP

SEC Enforcement Chief Andrew Ceresney Discusses CCO Liability

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On November 4, 2015, Andrew Ceresney, director of the Securities and Exchange Commission’s (SEC’s) Division of Enforcement (Enforcement Division), delivered the keynote address at the 2015 National Conference of the National...more

Thomas Fox - Compliance Evangelist

FCPA Compliance and Ethics Report-Episode 172-Scott Killingsworth on Personal Liability of CCOs

In this episode I visit with Scott Killingsworth on the recent SEC enforcement action in the SFX matter. In that case, the SEC held the CCO personally liability. We discuss the underlying facts, prior SEC pronouncements the...more

Bradley Arant Boult Cummings LLP

Avoiding personal liability amidst heightened AML enforcement

In February 2014, the Financial Industry Regulation Authority (FINRA), the self-regulatory body for the U.S. securities industry, suspended a former global anti-money laundering compliance officer at Brown Brothers Harriman &...more

Thomas Fox - Compliance Evangelist

FCPA Compliance and Ethics Report-Episode 122-with Matt Kelly on Alstom, Avon and Petrobras

In this episode, Compliance Week Editor-in-Chief Matt Kelly and I discuss the Avon and Alstom FCPA enforcement actions and then take a look at the ongoing Petrobras corruption scandal and what it means for Brazil. ...more

McGuireWoods LLP

SEC Seeks Serious Penalties Against Sands Brothers and its Senior Officers for Alleged Repeated Custody Rule Violations - Former...

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On October 29, 2014, the SEC announced that it had instituted administrative proceedings under the Investment Advisers Act of 1940 against Sands Brothers Asset Management LLC (Sands Brothers), its two co-founders and the...more

Stinson - Corporate & Securities Law Blog

When Will The SEC Bring An Action Against A Chief Compliance Officer?

In a couple of speeches at Compliance Week 2014, SEC officials spoke of when it would be appropriate to bring an enforcement action against a Chief Compliance officer, or CCO. SEC Commissioner Kara M. Stein said “If...more

Morrison & Foerster LLP

Compliance Overseers Under Financial Regulatory Fire

In the wake of the financial crisis, federal and state regulators are increasingly taking action against individuals for alleged compliance lapses inside financial services companies, and recent reports indicate that...more

Morrison & Foerster LLP

Financial Regulatory Enforcers Expanding Claims Against Individuals

In the wake of the financial crisis, federal and state regulators are increasingly taking action against individuals for alleged compliance lapses inside financial services companies, and recent reports indicate that...more

Thomas Fox - Compliance Evangelist

Individual FCPA Enforcement Actions In 2013

This year had the largest number of individual Foreign Corrupt Practices Act (FCPA) enforcement actions since 2010, the year of the Gun Sting case. Here are the highlights of FCPA related enforcement actions against...more

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