While it is unusual for a chief compliance officer to face government sanctions individually for compliance failures in the anti-corruption arena, the Securities and Exchange Commission and FINRA seem to be testing the waters. Last year, the SEC issued two enforcement actions against CCOs in the financial services section and, just this week, FINRA announced a disciplinary action against former Raymond James CCO Linda Busby. The penalty was drastic, as Busby, who was CCO from 2002 to 2013, agreed to leave the industry for three years and paid a fine of $25,000.
In its press release, FINRA enforcement chief Brad Bennett said, “Raymond James had significant systemic AML failures over an extended period of time, made even more egregious by the fact the firm was previously sanctioned in this area. The monitoring for suspicious transactions is an essential part of protecting our financial system and firms must allocate adequate resources to their AML compliance efforts. This case demonstrates that when there are broad-based failures within specific areas of responsibility, we will seek individual liability where appropriate.”
