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Administrative Law Litigation Regulations White Collar Crime

Compliance Officers: Law Enforcement Partners or Targets?

Part One of a Two-Part Article

Part One of this article examines key actions brought by U.S. regulators against compliance officers in 2017 based on their failures to ensure that their firms maintain effective compliance and AML programs.

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In May 2014, Andrew Ceresney, then-Director of Enforcement of the U.S. Securities and Exchange Commission (SEC), in his keynote address at Compliance Week 2014, stated, “ …. legal and compliance officers who perform their responsibilities diligently, in good faith, and in compliance with the law are our partners and need not fear enforcement action.” Andrew Ceresney, Director of Division of Enforcement, SEC, Keynote Address at Compliance Week 2014 (May 20, 2014). In the same speech, however, Ceresney articulated the circumstances under which the SEC would bring actions against compliance officers, personally: “[W]hen the [SEC] believes … compliance personnel have affirmatively participated in the misconduct, when they have helped mislead regulators, or when they have clear responsibility to implement compliance programs or policies and wholly failed to carry out that responsibility.” Id.

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