News & Analysis as of

Chief Compliance Officers Compliance Securities and Exchange Commission (SEC)

Society of Corporate Compliance and Ethics...

Implications of the SEC Cybersecurity Disclosure Rule

In 2023 the US Securities and Exchange Commission adopted rules “requiring registrants to disclose material cybersecurity incidents they experience and to disclose on an annual basis material information regarding their...more

SEC Compliance Consultants, Inc. (SEC³)

How Much Testing is Enough?

Most compliance officers struggle to determine whether they are conducting enough testing to satisfy their obligations under the Advisers Act. In its release adopting Advisers Act Rule 206(4)-7, the SEC stated that an...more

Society of Corporate Compliance and Ethics...

[Virtual Event] ESG and Compliance Conference - November 7th, 8:00 am - 5:00 pm CT

Stay on top of ever-evolving ESG requirements and emerging trends - With the SEC’s newly issued rules surrounding ESG disclosures and the continued growth of regulations rolling out in the EU, Canada, Asia and elsewhere...more

Thomas Fox - Compliance Evangelist

Lessons on Incentives and Discipline from Star Trek: Mirror Mirror

Last month, I wrote a blog post on the tone at the top, exemplified in Star Trek’s Original Series episode, Devil in the Dark. Based on the response, some passionate Star Trek fans are out there. I decided to write a series...more

Thomas Fox - Compliance Evangelist

Internal Reporting and Investigative Lessons from Star Trek: The Conscience of the King

Last month, I wrote a blog post on the tone at the top, exemplified in Star Trek’s Original Series episode, Devil in the Dark. Based on the response, some passionate Star Trek fans are out there. I decided to write a series...more

Thomas Fox - Compliance Evangelist

Internal Control Lessons from Star Trek: The Doomsday Machine

Last month, I wrote a blog post on the tone at the top, exemplified in the Star Trek, the Original Series episode, Devil in the Dark. Based on the response, some passionate Star Trek fans are out there. I decided to write a...more

Alston & Bird

CFTC Commissioner Warns That CCOs May Face Personal Liability

Alston & Bird on

Our Investment Funds Group reviews the implications of a Commodity Futures Trading Commission (CFTC) policy targeting chief compliance officers (CCOs) as individuals if their companies’ compliance programs fail....more

Thomas Fox - Compliance Evangelist

Supreme Court Rulings: A Compliance Perspective

Recently, the Supreme Court delivered several rulings that have caught the attention of compliance professionals. In this blog post, we’ll dissect these rulings and explore their implications for corporate compliance. Matt...more

SEC Compliance Consultants, Inc. (SEC³)

SEC Tells Advisers What Not to Do in Advertisements

SEC’s Division of Examinations (“EXAMS”) issued a risk alert on its Initial Observations Regarding Advisers Act Marketing Rule Compliance (the “Risk Alert”), giving compliance officers an unexpected gift by sharing examples...more

SEC Compliance Consultants, Inc. (SEC³)

Write the Best Annual Compliance Review Ever!

Many chief compliance officers struggle every year with preparing the annual review required under Advisers Act Rule 206(4)-7. To help you out, here’s our guide to writing your annual report....more

WilmerHale

Strategies For Navigating Compliance Monitorships

WilmerHale on

The imposition of an independent compliance monitor continues to be a favored tool of the government in resolving corporate enforcement matters. Indeed, in 2022, both the U.S. Department of Justice and the U.S. Securities...more

SEC Compliance Consultants, Inc. (SEC³)

Top Ten Reasons to Hire an RIA Compliance Consulting Firm

There are times when it makes sense to hire an expert. Securities regulations are complicated, and failure to comply can be costly, both in terms of fines and damage to reputation. Here are the top reasons registered...more

Kohn, Kohn & Colapinto LLP

Whistleblower Awards for Auditors are Key to Meeting OECD Guidelines

According to the Institute of Internal Auditors “Politics of Internal Auditing” (2015), 55% of chief audit executives were directed to commit important findings from their audit reports. 49% of chief audit executives were...more

American Conference Institute (ACI)

[Event] FCPA & Anti-Corruption for the Life Sciences Industry - May 9th - 10th, New York, NY

Hosted by the American Conference Institute, the 19th Annual FCPA & Anti-Corruption Conference for the Life Sciences Industry returns for another exciting year with carefully researched programming based on critical findings...more

NAVEX

Risk & Compliance as a Strategic Imperative for the Board

NAVEX on

In an era marked by heightened global regulatory scrutiny and enforcement, the landscape of risk and compliance is undergoing an evolution making the strategic imperative for effective, risk-based compliance initiatives...more

American Conference Institute (ACI)

[Event] Mexico Summit on Anti-Corruption & Compliance Program - March 13th - 14th, Mexico City, Mexico

ACI’s Mexico Summit on Anti-Corruption & Compliance Programs returns on March 13-14, 2024 in Mexico City! Given the uncertainty with the looming Presidential election, as well as increased U.S. enforcement focus on Mexico...more

ArentFox Schiff

Compliance Officers Beware: the SEC is Looking to Expand the Reach of Insider Trading

ArentFox Schiff on

On November 20, 2023, the Northern District of California denied summary judgment for the defendant in SEC v. Panuwat, an enforcement action being brought under a novel theory of insider trading law that is being referred to...more

American Conference Institute (ACI)

[Event] 17th Forum on the Foreign Corrupt Practices Act - January 24th - 25th, Houston, TX

As the most anticipated gathering for the community in Texas and the region, don’t miss out on re-connecting with your peers and more! With the continued focus on FCPA compliance and the anticipated rise in enforcement,...more

BakerHostetler

Culture, Cooperation and CCO Liability: SEC Enforcement Director Gurbir Grewal Gives Keynote Address at New York City Bar...

BakerHostetler on

On October 24, SEC Enforcement Director Gurbir Grewal addressed compliance professionals at the New York City Bar Association’s 2nd Annual Compliance Institute. His remarks focused on three topics: creating “a culture of...more

American Conference Institute (ACI)

[Event] 40th International Conference on the FCPA - November 28th - 30th, National Harbor, MD

Hosted by American Conference Institute, the 40th International Conference on the FCPA returns for another exciting year with curated programming that shines a global spotlight on anti-corruption compliance challenges,...more

Skadden, Arps, Slate, Meagher & Flom LLP

SEC Enforcement Division Director Clarifies Approach to Compliance Officer Liability

In a speech on October 24, 2023, the director of the Securities and Exchange Commission’s (SEC’s) Enforcement Division, Gurbir Grewal, described the scenarios in which the commission would bring an enforcement action against...more

Alston & Bird

SEC Enforcement Director Clarifies Compliance Violation and CCO Liability

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Our Investment Funds and White Collar Teams interpret how the Securities and Exchange Commission approaches its enforcement in three aspects: whistleblower restraints, self-reporting and cooperation, and compliance officer...more

Bressler, Amery & Ross, P.C.

SEC Enforcement Chief Issues Reminder Concerning Compliance Officer Liability

On Oct. 24, 2023, Gurbir Grewal, the Director of the U.S. Securities and Exchange Commission’s (SEC) Enforcement Division, spoke to the NY Bar Association Compliance Institute about his views concerning faltering public trust...more

A&O Shearman

SEC Brings Charges Under Enforcement Initiative Directed at Insider Report Compliance Failures

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On September 27th, 2023, the SEC brought charges against six officers, directors and major shareholders of public companies for repeated failures to make timely filings pursuant to Section 13 and Section 16 of the Securities...more

A&O Shearman

FCPA Digest - Recent Trends and Patterns in the Enforcement of the Foreign Corrupt Practices Act - June 2023

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In 2022, the DOJ and the SEC resolved a total of ten corporate enforcement actions under the FCPA, more than double the number in the previous year. While the average corporate penalties only slightly increased to $168...more

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