Thoughts on Training and CCO Certifications

training

So there I was the other day, talking with a compliance officer who helps with training at a large global corporation. We were chatting about a fairly common question in the field: should companies allow people to test out of compliance training if they already know the subject matter?  That’s a complicated question unto itself,…

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On Compliance Officers Certifying Their Programs

certifications

Folks, we need to talk about the Justice Department’s new idea to have chief compliance officers certify at the end of a deferred-prosecution agreement that their company’s compliance program is reasonably designed and effective. I am a fan of the Justice Department and strong compliance programs — but can something like this really work in…

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FINRA’s Olive Branch on CCO Liability

cco liability

FINRA, the regulator for broker-dealer firms, is trying to ease tensions over chief compliance officer liability with a new alert stressing that FINRA typically will not bring enforcement actions against CCOs personally because compliance officers don’t inherently have a supervisory role at their firms.  FINRA published the alert late last week, after several pleas from…

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Analyzing the Latest CCO Liability Case

cco liability

Stop me if you’ve heard this one before: a chief compliance officer faces personal legal liability for compliance failures at his firm, and everyone got into a tizzy over it. Then, upon reading the facts of the case, a more complicated picture emerges that demonstrates just how tricky a subject CCO liability can be.  Such…

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Another CCO Liability Proposal

cco liability

The National Society of Compliance Professionals, which represents compliance officers specifically in the financial services world, has released a proposed framework to help regulators understand the threat of chief compliance officer liability and when such liability is or isn’t warranted for a compliance failure. The NSCP released its framework on Monday: a series of nine…

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Goldman Compliance Officer Busted on Insider Trading

cco liability

A senior compliance analyst at Goldman Sachs has been charged with insider trading by the SEC, which says the man racked up more than $470,000 ill-gotten profits by trading in brokerage accounts held under his parents’ names.  The man, Jose Luis Casero Sanchez, worked in the control room of Goldman’s offices in Warsaw, Poland, from…

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Proposed: Framework for CCO Liability

cco liability

The New York City Bar Association has proposed a framework that the Securities & Exchange Commission should follow when deciding whether to charge a chief compliance officer for compliance failures at his or her firm.  The framework, announced to the world on Wednesday, addresses points such as when a CCO should be charged for “wholesale…

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Cruise Lines Face Covid-19 Compliance Squeeze

cruise

Royal Caribbean International has agreed to an exhausting set of criteria from the Centers for Disease Control so the cruise line can evacuate its employees from ships stuck at sea — including the risk of civil and criminal penalties for senior executives should Royal Caribbean bungle the task. That certainly takes the importance of running…

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Report Urges Action on CCO Liability

cco liability

The New York City Bar Association released a report on Tuesday warning that compliance officer liability continues to be a worrisome part of regulatory enforcement, and called for more guidance about when a compliance officer’s conduct can leave him or her in regulators’ crosshairs. The report focused on compliance officers working in financial services firms,…

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Feds: SEC Staffer Stole Data to Land CCO Role

cco liability

Oh good lord: Federal prosecutors have indicted a former SEC enforcement attorney with stealing information from the agency while he worked there — so he could set himself up as chief compliance officer of a private equity firm under SEC investigation. Michael Cohn, chief compliance officer of GPB Capital Holdings, was charged in federal court…

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