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The SEC (Sort of) Weighs In on How Personal Liability for Chief Compliance Officers May Undercut Effective Compliance Programs

December 14, 2020 | Compliance Risk + Compliance

Although regulators often seek to empower compliance officers within their institutions, a troubling question lingers as to whether regulators are undercutting this important message by simultaneously sending mixed or unrefined signals about when a Chief Compliance Officer should be held personally liable for the compliance failings of his or her firm. The director of the U.S. Securities and Exchange Commission’s Office of Compliance Inspections and Examinations recently urged investment firms to empower Chief Compliance Officers (CCOs), saying, “The CCO is … Read More

Apple Insider Trading Case Underscores Basics of Effective Internal Investigations

March 1, 2019 | Investigations

Lesson From Apple

The Securities and Exchange Commission recently filed a lawsuit against a former Apple executive alleging he engaged in insider trading. According to the SEC’s complaint, as the previous global head of corporate law and corporate secretary, he was responsible for ensuring that employees complied with the company’s policy on insider trading. He also received material non-public information about Apple’s finances as a member of the company’s disclosure committee. The SEC alleges he, on at least three occasions, … Read More