The issue of chief compliance officer (CCO) liability has long been debated; it has become a grave concern for CCOs, CEOs, and other C-suite executives who put on “too many hats” within.
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I have always played down the issue of CCO liability and prosecutions. I dismiss these concerns often because the reporting of CCO prosecutions are usually exaggerated and meant to instill fear in compliance professionals. In my simplistic approach, I have followed the general rule of thumb – if you do something wrong, you pay the price. In a number of cases involving compliance officer prosecutions, the compliance professional engaged in obvious wrongdoing and “deserved” whatever sanction was meted out. After all, no one can argue that “every” compliance officer is an angel.