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.
