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Escalation Processes to Avoid Personal CCO Liability

Jose Tabuena | February 24, 2015

Compliance officers and their staff have become more concerned lately about exposure to personal liability, since recent regulatory actions have shown them to be at risk.

The argument for that liability is this: Compliance is expected to know the regulations and how they apply to the business model, and so a CCO should recognize violations more readily. Compliance officers typically know more than the business-line folks whom they advise regarding the regulatory requirements for the company’s operations. As compliance often communicates periodically with government agencies, a retrospective...

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