- Chief Compliance Officer and VP of Legal Affairs, Arrow Electronics
By 
Aaron Nicodemus2022-07-21T16:00:00
Communication between the Securities and Exchange Commission and the compliance community is not happening as robustly as compliance practitioners would like. The result is compliance officers are more concerned than ever the agency will target them in an enforcement action.
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SEC Commissioner Mark Uyeda called for the agency to establish a framework that would describe scenarios in which a chief compliance officer would be held liable for securities law violations made by their firm.
To see a prominent representative from the CFTC accuse the SEC of “regulation by enforcement” might raise the eyebrow of some observers. But it shouldn’t—not when that’s the latter’s stated strategy.
What would it look like if the SEC adopted a chief compliance officer liability framework? Commissioner Hester Peirce offered a preview in a statement regarding an enforcement action against the CCO of a formerly registered investment adviser.
Top-of-mind issues addressed at Compliance Week’s Third-Party Risk Management & Oversight Summit, held June 3-4 in Atlanta, included safe deployment of artificial intelligence, assessing vendor viability and sustainability, understanding the role of procurement in risk ranking, the intersection (or lack thereof) between data privacy and cybersecurity, and many others.
Anne Morriss, co-author of “Move Fast and Fix Things,” advises compliance officers to tap into curiosity, communicativeness, and comfort with discomfort to build organizational trust, fast.
Regulators and government agencies often speak to the value of empowered corporate compliance programs to advancing their mission. Why not practice what they preach by empowering compliance among their own ranks?
