The debate has intensified over when, and how, compliance officers may find themselves the subject of an enforcement action by the Securities and Exchange Commission.

Recent statements by commissioners include Chairman Mary Jo White assuring CCOs they are not being targeted, Luis Aguilar suggesting there is “unwarranted fear,” and Daniel Gallagher citing actions against Blackrock Advisors and SFX Financial Advisory Management Enterprises to suggest that “the SEC is overreaching” with its application of the Investment Advisers Act when punishing compliance personnel at those firms.