Session 2: Tactical Steps to Protect the CCO from Liability

With the ever-increasing pace of new regulations, products, and technological advances, in addition to the lingering effects of the global pandemic and instability of the financial markets, the job of the compliance officer has never been more complex.   The recent regulatory actions focusing on Chief Compliance Officer liability have only served to amplify the difficulty of the role.  The panelists will review some of the “lessons learned” from recent enforcement actions and suggest common sense, tactical ways to help CCOs perform their job effectively, take steps to avoid personal liability, and advance compliance responsibility across the organization.

Learning Objectives: 

• Review recent CCO liability enforcement actions, New York State Department of Financial Services (NYFSD) and NSCP Frameworks for Compliance Officer Liability, and DOJ Compliance program certification requirements

• Evaluate ways that can best evidence the CCO’s oversight of compliance and steps to mitigate circumvention of the compliance program through use of case studies which will include a discussion of supervision and compliance officer responsibilities

• Discuss practical ways compliance officers can strengthen a culture of compliance among business partners at all levels within an organization

• Determine when and if a compliance officer must step out of the CCO role