Insights

Chief Compliance Officers Now Personally Liable for Failing Compliance Programs

September 22, 2015

Management Liability/D&O

I recently wrote about compliance personnel noting that they are now eligible to be paid whistleblower bounties. It’s not, however, all puppies and rainbows for compliance officers  – especially chief compliance officers.

Instead, the Securities and Exchange Commission has recently demonstrated its interest in pursuing CCOs personally in certain circumstances where their companies’ compliance programs fail.

My colleague Jacob Decker – who is an expert on and writes about financial institutions – tackled this issue in a recent article. Jacob’s article is of particular interest because it illustrates the trend of government agencies bringing more enforcement actions against individuals, including in their supervisory capacities.

The situation in Jacob’s article may also presage future targeting of general counsel and CCOs of public companies whose employees run afoul of the SEC’s rules and regulations.

This is something we’ll keep an eye on. In the meantime, here’s a link to Jacob’s article with more about the SEC enforcements and how to protect CCOs.

 

The views expressed in this blog are solely those of the author. This blog should not be taken as insurance or legal advice for your particular situation. Questions? Comments? Concerns? Email: phuskins@woodruffsawyer.com.

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All views expressed in this article are the author’s own and do not necessarily represent the position of Woodruff-Sawyer & Co.

Priya Cherian Huskins

Senior Vice President, Management Liability

Editor, Management Liability/D&O

Priya is a recognized expert and frequent speaker on D&O liability risk and its mitigation. In addition to consulting on D&O insurance, she counsels clients on corporate governance matters, including ways to reduce their exposure to shareholder lawsuits and regulatory investigations. Priya serves on the board of an S&P 500 public company and a large private company and has an impressive list of publications, speaking engagements, and awards for her influence and expertise in the industry. 

415.402.6527

LinkedIn

Priya Cherian Huskins

Senior Vice President, Management Liability

Editor, Management Liability/D&O

Priya is a recognized expert and frequent speaker on D&O liability risk and its mitigation. In addition to consulting on D&O insurance, she counsels clients on corporate governance matters, including ways to reduce their exposure to shareholder lawsuits and regulatory investigations. Priya serves on the board of an S&P 500 public company and a large private company and has an impressive list of publications, speaking engagements, and awards for her influence and expertise in the industry. 

415.402.6527

LinkedIn