The Securities and Exchange Commission (SEC) continues to ratchet up its pressure on the chief compliance officer (CCO) of registered investment advisers (RIA) and broker-dealers after reaching settlements in two recent Division of Enforcement cases, both of which required the individual CCO to personally pay a substantial monetary fine as part of those settlements.1 SEC commissioners continue to publicly debate the value and efficacy of such settlements against individual CCOs, whether a strict liability standard is being imposed on CCOs, and therefore whether such cases will create a chilling effect on the compliance officer community.2

It is instructive to start with a recent speech on CCO liability by SEC Chair Mary Jo White.

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