Daily Compliance News: July 29, 2025 the Is CEO Conduct Ever Personal Edition
When a co-shareholder purchases the debt obligations of the company without partners' knowledge
Takeaways From Recent Claims Against Mark Zuckerberg and Facebook – Mitigating the Heightened Risk of Privacy Suits Against Individual Directors and Officers
Law School Toolbox Podcast Episode 280: Listen and Learn -- Piercing the Corporate Veil
Bar Exam Toolbox Podcast Episode 120: Listen and Learn -- Piercing the Corporate Veil
Compliance Perspectives: Compliance Officer Liability Risk
Lawyers on Tap: Tap Tips for Entity Formation and Taxation
FCPA Compliance Report-Episode 329, James Koukios
The Insider Trading Cartoon Series, Vol. XII -- The Innocent Intermediary
FCPA Compliance and Ethics Report-Episode 172-Scott Killingsworth on Personal Liability of CCOs
FCPA Compliance and Ethics Report Episode 129-Judge Rakoff, Judge Leon and Individual Prosecutions Under the FCPA
FCPA Compliance and Ethics Report-Episode 122-with Matt Kelly on Alstom, Avon and Petrobras
What Are the Drastic Ramifications of the New York State Anti-Money Laundering Actions and Penalty Enforcement?
Before committing to a franchise business, consider...
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
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
On October 24, SEC Enforcement Director Gurbir Grewal addressed compliance professionals at the New York City Bar Association’s 2nd Annual Compliance Institute. His remarks focused on three topics: creating “a culture of...more
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
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
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
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
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
The New York City Bar Association Compliance Committee (“Committee”) recently issued a report encouraging financial regulators to provide a clear framework for when compliance officers may be held personally liable for the...more
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
A horse is a horse, of course, of course, and no one can talk to a horse, of course. That is, of course, unless the horse is the famous Mister Ed. Those lines were the opening verse to the theme song of the TV...more
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
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
On the accountability and punishment front, three trends bear watching: 1) Deferred Prosecution Agreements (DPAs) DPAs and Non-Prosecution Agreements (NPAs) allow prosecutors to require corporate reforms and...more
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
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
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