With the implementation of the Volcker Rule, the Securities and Exchange Commission (SEC) is poised to hold compliance officers personally responsible for their companies’ failures. If a business is like a football team, the chief compliance officer (CCO) may end up like the starting left tackle. If he does not protect the quarterback, he’ll lose his job. Now, if the CCO fails to do everything possible to prevent a compliance breach, then he or she may be the one facing penalties.
“There’s been lots of press around pretty strong enforcement of laws, hefty fines and that sort of thing. A number of companies have been heavily fined,” says Jodi Golinsky, a seasoned in-house lawyer with compliance experience at a number of financial institutions. “This has led to a greater emphasis on a culture of compliance, building up to levels greater than we have seen before.”
