How CCOs Can Avoid Personal Liability for an Organization’s Compliance Failures

As the role of CCO becomes increasingly important, CCOs may draw unwelcome regulatory scrutiny and, in certain cases, face personal liability for their organizations’ compliance failures. In this article, we cover regulators’ perspectives on CCO liability, the facts and circumstances that gave rise to personal liability for CCOs in recent enforcement actions, enforcement takeaways and best practices for CCOs, as discussed at a recent Society of Corporate Compliance and Ethics program. See “NYC Bar Report on CCO Liability Calls for More Regulatory Guidance, Transparency and Cooperation” (Apr. 15, 2020).

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