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Personal Liability › Policies and Procedures › Enforcement Actions

Foley & Lardner LLP

SEC Intensifies Scrutiny of Chief Compliance Officers

Foley & Lardner LLP on

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

Oberheiden P.C.

OFAC Compliance: Avoiding Common Root Causes of Compliance Policy Breakdowns and Deficiencies

Oberheiden P.C. on

For financial institutions and businesses that are subject to the oversight of the Office of Foreign Assets Control (OFAC), compliance needs to be a priority in 2023. OFAC is playing an increasingly active role in overseeing...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...

Eversheds Sutherland (US) LLP on

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

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