Posts Tagged ‘cco liability’
Financial CCOs Propose SEC Advisory Group
The professional association for compliance officers in the financial services industry has asked the Securities and Exchange Commission to form a Compliance Advisory Committee, so that compliance officers at regulated firms can have a stronger voice in SEC policy matters that might affect them. The National Society of Compliance Professionals, which caters to compliance officers…
Read MoreFINRA Sanctions Two Compliance Officers
Corporate compliance officers are always interested in regulatory enforcement actions against one of their own, so today let’s take a close look at an enforcement action against two compliance officers handed down earlier this week for poor oversight of their firm’s compliance program. The enforcement action came from FINRA, the regulator for broker-dealer firms. The…
Read MoreFormer Wells Fargo Execs Fined Millions
Three of the top risk assurance executives at Wells Fargo during its fake accounts scandal in the 2010s must all pay millions in fines for failing to challenge the bank’s misconduct aggressively enough — a dose of individual accountability that sounds good in theory, but might still leave audit, compliance, and risk management professionals rather…
Read MoreSolarWinds, Part III: ‘Following’ the NIST Framework
Today we return to the lawsuit the Securities and Exchange Commission has filed against SolarWinds, the IT services firm that suffered a disastrous cyber attack in 2020. How much does SolarWinds’ compliance with the NIST framework for cybersecurity — or its lack thereof — figure into this risk management morass? Quite a lot, at least…
Read MoreSolarWinds, Part II: This Is Not New
Today we continue our look at that lawsuit filed by the Securities and Exchange Commission against SolarWinds and its CISO for poor disclosure of the company’s cybersecurity issues. As unsettling as this case might be for compliance and audit professionals, is it really a ground-breaking moment in securities enforcement? Perhaps not. Let’s first appreciate what…
Read MoreA Deep Dive Into SEC’s SolarWinds Lawsuit
Heads up, compliance and internal audit professionals! The Securities and Exchange Commission just filed a potentially profound lawsuit against the tech company SolarWinds and its CISO for misleading investors about the state of that company’s cybersecurity defenses — defenses that were proven toothless during a cybersecurity breach in 2020. The lawsuit, filed Monday against SolarWinds…
Read MoreFresh Glimpses Into SEC Enforcement
The head of enforcement at the Securities and Exchange Commission has been on a bit of a publicity tour this week, making several speeches about the importance of strong compliance functions, enforcement measures such as monetary penalties and “compliance consultants,” and other issues dear to compliance professionals’ hearts. Most notably, enforcement chief Gurbir Grewal spoke…
Read MorePodcast: Delaware Law & Officer Liability
We have another Radical Compliance podcast today, this time talking about that recent Delaware Chancery Court ruling that opens the door to more personal liability risks for chief compliance officers and other corporate executives. To parse the implications of that ruling I called up Todd Haugh, professor of business ethics and law at Indiana University.…
Read MoreSEC Nails Activision on Culture Oversight
Activision-Blizzard has agreed to pay $35 million to settle charges from the Securities and Exchange Commission that the company didn’t have adequate processes to warn investors about its poor corporate culture. The company also settled charges that it violated whistleblower protection rules. The settlement was announced Friday morning, and I fear that this case may…
Read MoreDuty of Oversight, Part II
Today let’s take a closer look at that Delaware Chancery Court decision from last week that established a “duty of oversight” for corporate officers. It’s another evolutionary step in the oversight of corporate culture, which is always something corporate compliance and audit professionals need to watch closely. The decision involved the former head of HR…
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