Last week, yet another US Department of Justice (DOJ) official reportedly stated new corporate settlements “most likely” will include a requirement that the company’s chief compliance.
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The staff of the Securities and Exchange Commission’s Office of Compliance Inspections and Examinations (staff) issued a Risk Alert on November 19, 2020 (Risk Alert), related to OCIE’s observations regarding deficiencies in investment adviser compliance programs.
1 The Risk Alert is intended to share OCIE’s observations on “notable compliance issues” found in recent examinations of SEC-registered investment advisers (advisers) related to Rule 206(4)-7 (Compliance Rule) under the Investment Advisers Act of 1940, which issues are “among the most common cited by OCIE” according to the Risk Alert. The Risk Alert groups the staff’s observations into six categories: inadequate compliance resources; insufficient authority of Chief Compliance Officers (CCOs); annual review deficiencies; implementing actions required by written policies and procedures; maintaining accurate and complete information in policies and