News & Analysis as of

Securities and Exchange Commission (SEC) Enforcement Actions Chief Compliance Officers

Proskauer Rose LLP

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

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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

DLA Piper

Key Considerations for Compliance Officers Under President Trump

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The Trump Administration has ushered in massive shifts in enforcement and policy priorities. From crypto to anti-corruption measures and tariffs to technology, the new Administration has changed the compliance landscape...more

American Conference Institute (ACI)

[Event] 2nd National Conference on Cybersecurity Law & Compliance - January 29th - 30th, Arlington, VA

Cyberattacks are affecting every company and sector. Meanwhile, the regulatory landscape is intensifying as the SEC continues to enforce the cyber-risk management disclosure rules. Every day presents a new compliance and...more

Bass, Berry & Sims PLC

[Webinar] ESG Outlook: Preparing for the 2025 Reporting Season - December 17th, 12:00 pm - 1:00 pm CST

Bass, Berry & Sims PLC on

Join Bass, Berry & Sims and leading environmental, social, and governance (ESG) along with corporate and securities thought leaders for the next installment of our ESG Impact Webinar series. As public companies prepare for...more

American Conference Institute (ACI)

[Event] Mexico Summit on Anti-Corruption & Compliance Program - March 13th - 14th, Mexico City, Mexico

ACI’s Mexico Summit on Anti-Corruption & Compliance Programs returns on March 13-14, 2024 in Mexico City! Given the uncertainty with the looming Presidential election, as well as increased U.S. enforcement focus on Mexico...more

ArentFox Schiff

Compliance Officers Beware: the SEC is Looking to Expand the Reach of Insider Trading

ArentFox Schiff on

On November 20, 2023, the Northern District of California denied summary judgment for the defendant in SEC v. Panuwat, an enforcement action being brought under a novel theory of insider trading law that is being referred to...more

American Conference Institute (ACI)

[Event] 17th Forum on the Foreign Corrupt Practices Act - January 24th - 25th, Houston, TX

As the most anticipated gathering for the community in Texas and the region, don’t miss out on re-connecting with your peers and more! With the continued focus on FCPA compliance and the anticipated rise in enforcement,...more

American Conference Institute (ACI)

[Event] 40th International Conference on the FCPA - November 28th - 30th, National Harbor, MD

Hosted by American Conference Institute, the 40th International Conference on the FCPA returns for another exciting year with curated programming that shines a global spotlight on anti-corruption compliance challenges,...more

Skadden, Arps, Slate, Meagher & Flom LLP

SEC Enforcement Division Director Clarifies Approach to Compliance Officer Liability

In a speech on October 24, 2023, the director of the Securities and Exchange Commission’s (SEC’s) Enforcement Division, Gurbir Grewal, described the scenarios in which the commission would bring an enforcement action against...more

Alston & Bird

SEC Enforcement Director Clarifies Compliance Violation and CCO Liability

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Our Investment Funds and White Collar Teams interpret how the Securities and Exchange Commission approaches its enforcement in three aspects: whistleblower restraints, self-reporting and cooperation, and compliance officer...more

A&O Shearman

SEC Brings Charges Under Enforcement Initiative Directed at Insider Report Compliance Failures

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On September 27th, 2023, the SEC brought charges against six officers, directors and major shareholders of public companies for repeated failures to make timely filings pursuant to Section 13 and Section 16 of the Securities...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

American Conference Institute (ACI)

[Event] 18th Annual FCPA & Anti-Corruption for the Life Sciences Industry - May 10th - 11th, New York, NY

Hosted by American Conference Institute, the 18th Annual Conference on the FCPA & Anti-Corruption for the Life Sciences Industry returns for another exciting year with curated programming that shines a global spotlight on...more

Society of Corporate Compliance and Ethics...

[Virtual Event] Corporate Compliance Enforcement Conference - July 25th, 9:00 am - 4:45 pm CT

Is Your Compliance Program Designed for the Current Enforcement Landscape? Data protection, anti-corruption, antitrust, supply chains, economic sanctions and even the software employees use to communicate are all subjects...more

Thomas Fox - Compliance Evangelist

Profit Sharing as Bribery: The Honeywell FCPA Enforcement Action: Part 1 – Introduction

To close out 2022 in Foreign Corrupt Practices Act (FCPA) enforcement actions, the Department of Justice (DOJ) and Securities and Exchange Commission (SEC) both announced settlements of FCPA enforcement actions with Honeywell...more

Troutman Pepper Locke

Lessons From SEC Enforcement Actions Involving Corporate Lawyers

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The Securities and Exchange Commission (“SEC”) has recently brought several enforcement actions that directly or indirectly involved lawyers. These actions provide reminders to lawyers of their professional responsibility in...more

Eversheds Sutherland (US) LLP

A Tale of Two Enforcement Actions Against Compliance Officers: An analysis applying the NSCP Firm and CCO Liability Framework

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

UB Greensfelder LLP

Determining Chief Compliance Officer Liability Isn’t Really That Confounding

UB Greensfelder LLP on

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

Eversheds Sutherland (US) LLP

DOJ to place additional burdens on CCOs

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

A&O Shearman

FINRA Issues Regulatory Notice On The Scope Of Supervisor Liability For Chief Compliance Officers

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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

Burr & Forman

FINRA Clarifies CCO Supervisory Liability

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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

Society of Corporate Compliance and Ethics...

[Event] Regional Compliance & Ethics Conference - March 28th, Phoenix, AZ

Looking for compliance training and networking in your area? SCCE’s Regional Compliance & Ethics Conferences offer practitioners convenient, local compliance training, including updates on the latest news in regulatory...more

Society of Corporate Compliance and Ethics...

[Virtual Event] Corporate Compliance Enforcement Conference - April 6th, 8:55 am - 3:30 pm CDT

Learn from today’s enforcement leaders and get the answers to your most pressing questions - Want to take an unfiltered look at issues like global data protection, whistleblowing, and more from a prosecutor’s or...more

Thomas Fox - Compliance Evangelist

2021 – The Year in FCPA Enforcement

There was a paucity of Foreign Corrupt Practices Act (FCPA) enforcement actions in 2021. However, the few enforcement actions announced did provide significant lessons for every compliance professional....more

A&O Shearman

Comments At SEC Speaks Conference Suggest Heightened Bar For Cooperation Credit, Return Of Admissions Policy, And Increased...

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On October 13, 2021, SEC Enforcement Director Gurbir Grewal and Deputy Enforcement Director Sanjay Wadhwa appeared at the Practicing Law Institute’s “The SEC Speaks” conference, an annual conference where Commission leaders...more

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