Outside Publication

SEC's Friendly Fire Against CCOs — And How To Avoid It, Law360

August 10, 2015

The U.S. Securities and Exchange Commission has long recognized that chief compliance officers and other legal and compliance personnel serve the public interest as the first line of defense against misconduct.

Recently, the agency brought two separate settled enforcement actions against CCOs of investment advisory firms for allegedly being “a cause” of their respective firm’s compliance failure. In doing so, the SEC charged these CCOs for what it viewed to be mere negligence on the part of the CCOs in performing their purely compliance functions.

Read the article >>