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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

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

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

Pun-ishment by SEC and FINRA: Enforcement Actions in March 2021

When you think about it, puns are kind of like securities enforcement actions. They could make you groan; they could make you laugh (if the conduct is particularly goofy) (or if you don’t like the respondent); or they often...more

How You Doin’: Friends and SEC/FINRA Enforcement from February 2021

Many of us watched Friends when it was originally broadcast using our rabbit ear antennas or through basic cable. Others watched it on reruns. While, more recently, some of us (or our children) watched on Netflix or, even...more

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