On October 24, 2023, the Director of the Securities and Exchange Commission’s Enforcement Division, Gurbir S. Grewal, gave a keynote address to the New York City Bar Association’s 2023 Compliance Institute.
This address, which was targeted primarily at compliance officers in the private funds space, represents a maturation in how the Enforcement Division views the role of the Chief Compliance Officer. This new framework may represent a “New Deal for CCOs,” which signals some fairly rigorous expectations and requirements on CCOs and other legal and compliance officers.
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