In October 2023, FINRA brought a settled case against a chief compliance officer (CCO) because his firm allegedly had inadequate procedures pertaining to excessive trading. For this violation, the CCO wasn’t charged for supervisory failures; he didn’t affirmatively participate in misconduct unrelated to his compliance function; he didn’t intentionally help to mislead regulators; and there is no evidence that he exhibited a wholesale failure to carry out his responsibilities. Nonetheless, he was charged and sanctioned. Is this an example of the proverbial canary in a coal mine?
‘Enforcement 40’ for 2020
Join Us On LinkedIn
Join the Securities Litigation and Enforcement Group on LinkedIn