Chief Compliance Officers Now Personally Liable for Failing Compliance Programs

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:



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