This article, like its predecessors, analyzes recent SEC and FINRA actions against CCOs to highlight examples of conduct that regulators have identified as sanction-worthy, in the hope that others may avoid a similar disciplinary branding in the future. From November 2010 through June 2011, the SEC and FINRA brought disciplinary actions against CCOs for a range of conduct, including playing a role in their respective firms’ inadequate due diligence of private placement products, failing to supervise registered representatives, aiding and abetting their firms’ underlying violations, permitting an unregistered individual to trade securities, failing to preserve emails and failing to provide anti-money laundering supervision.
‘Enforcement 40’ for 2020
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