Chief Compliance Officers

News & Analysis as of

SEC Sanctions Adviser, Executives and CCO for Custody Rule Violation – Again

On November 19, 2015, the SEC sanctioned a registered investment adviser, its two owners, and a former chief compliance officer for violating the Advisers Act “custody rule” after previously settling similar charges and...more

Win-Wins: Looking for Business and Compliance Success

A Chief Compliance Officer who lacks working relationships with the business side of a company is like a day without sunshine. No matter how strong or finely tuned a compliance program is on paper – in practice, the success...more

Brother Can You Spare Some (Compliance) Advice?

Usually I have Houston professional sports teams to hold high as example of true bone headedness around compliance issues. However, as my beloved Houston Astros took the World Series Champions, KC Royals, to the 7th inning of...more

SEC Exam Staff Shares Observations on Outsourced Chief Compliance Officers

Firms that use third-party CCOs or that rely on financial intermediaries that have outsourced their compliance functions should consider taking a fresh look at their compliance structure in the wake of this guidance....more

Final Rule Issued: Stark Law Modifications Designed to Ease the Burden of Compliance

On October 30, 2015, the Centers for Medicare and Medicaid (“CMS”) issued a final regulation that includes modifications to the Stark Law (the “Final Rule”). Among other things, the Final Rule adds two new exceptions to the...more

How Does an Antitrust Compliance Program Meet DOJ Standards? For the First Time, the DOJ Explains

For the first time, the Department of Justice has described what makes a company-imposed antitrust compliance pro­gram effective enough to earn a recommended lowering of the antitrust fine under the Unit­ed States Sentencing...more

Bridging the Week - November 2015 #3

Court Chastises SEC for Causing Unwarranted Collapse of Foreign Bank: A federal judge in New York severely criticized the Securities and Exchange Commission over its handling of a lawsuit against Caledonian Bank Ltd.,...more

Reading Minds: 5 Ways to Understand a Board of Directors, from the Inside-Out

Compliance managers and leaders offer a common compliant in our roundtables: “no one really listens to us”. It would seem this isn’t imagined. Steven Cohen, Assistant Director of the SEC, said recently, “We are very mindful...more

[Webinar] Corruption and Third Parties: Top Ways to Mitigate Risks - Dec. 1st, 12:00pm EST (3:00pm Brazil)

New laws, increased enforcement and broadened liability increase the urgency for companies working in Brazil to put processes in place to prevent corruption within their own organizations and among their business partners....more

Compliance Counsel Metrics – Part III: Program Evolution and Incentivizing Compliance

Today, we continue our exploration of the new Department of Justice (DOJ) Compliance Counsel and the metrics laid out by Assistant Attorney General Leslie R. Caldwell who called for her review of compliance programs. These...more

OCIE Issues Risk Alert Relating to Outsourced Chief Compliance Officers

On November 9, 2015, the Office of Compliance Inspections and Examinations (“OCIE”) released the findings of its Outsourced CCO Initiative, which examined nearly 20 investment advisers and investment companies that are...more

SEC Releases Risk Alert Related to Outsourcing of Chief Compliance Officer Duties by Investment Advisers and Investment Companies

On Nov. 9, the SEC’s Office of Compliance Inspections and Examinations (OCIE) released a risk alert reporting observations from its examination of investment advisers and investment companies that outsource their Chief...more

Modern Slavery Act 2015 - Supply Chain Transparency – new legal duties now in force

The Modern Slavery Act 2015 (MSA) has introduced a new obligation on businesses to report what they are doing to combat slavery and human trafficking....more

Financial Services Weekly News - November 2015 #2

Regulatory Developments: CFTC and NFA Staff Publish FAQs and Other Resources for Filing and Reporting on Forms CPO-PQR and CTA-PR - On Nov. 5 the Division of Swap Dealer and Intermediary Oversight of the CFTC...more

Turning the CEO Around: How to Make Sure the CEO Embraces Ethics and Compliance

Your CEO is either on board for compliance, or he/she is not. There is no half-way mark here, no way to deceive or soft-shoe your way through the compliance requirement....more

OCIE Cautions Advisers About Outsourcing Compliance Activities

In a Risk Alert dated November 9, 2015, the SEC’s Office of Compliance Inspections and Examinations (OCIE) said it found that outsourced compliance programs are generally effective, but some of these arrangements leave room...more

Bridging the Week - November 2015 #2

Jury Convicts Michael Coscia of Commodities Fraud and Spoofing: After a seven-day trial in Chicago, Michael Coscia was convicted last week of six counts of commodities fraud and six counts of spoofing in connection with...more

Does Training + Code of Ethics = Culture of Ethics?

Complacency in compliance is a cancer on a company’s culture. Woody Allen said it best in Annie Hall: A [compliance program] relationship, I think, is like a shark. You know? It has to constantly move forward or it dies. And...more

DOJ Announces New Compliance Counsel and Outlines Metrics for Evaluating Corporate Compliance Programs Under Scrutiny

In July 2015, the U.S. Department of Justice’s Criminal Division revealed that it was hiring a Compliance Counsel to assist in assessing the quality and effectiveness of companies’ corporate compliance programs under scrutiny...more

Corporate Responsibility for Third-Party Misconduct: The UK Modern Slavery Act of 2015

Companies have long faced serious legal consequences for bribes paid by employees, vendors, suppliers, business partners and other third parties with whom they do business. More recently, that risk has expanded beyond bribery...more

FinCEN Proposes Anti-Money Laundering and Suspicious Reporting Rules for Registered Investment Advisers

On August 25, 2015, the US Treasury Department’s Financial Crimes Enforcement Network (FinCEN) proposed rules that would require registered investment advisers to adopt anti-money laundering (AML) programs and report...more

Good-Bye to Fred Thompson – What’s Your Compliance Plan?

Fred Thompson died this week. He had a long and distinguished government career including working in the Senate Watergate Committee as a staffer. Thompson was credited for coming with the signature question from the Watergate...more

Celebrate Compliance Week 2015

November 1-7 is Compliance and Ethics Week. I wanted to give you some ideas on how you might use this week’s designation to help bring the message of compliance and ethics to your organization. An oft-raised topic is how to...more

SEC Discusses Criteria for Charging Chief Compliance Officers

In remarks before the 2015 National Society of Compliance Professionals, National Conference, Andrew Ceresney, Director, SEC Division of Enforcement, outlined the type of criteria used to charge Chief Compliance Officers with...more

[Event] 2015 Ethics & Compliance Virtual Conference - Nov. 17th, Virtual

Don't miss the largest ethics & compliance industry event of the year! Brand New Topics & Sessions! * Hear nine engaging sessions—including our Keynote by Governor Thomas J. Ridge—and gain practical takeaways to...more

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