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The Watchdogs Are Being Watched  


Author:  Jay A. Dubow.; Ying Zeng.


Source: Volume 51, Number 19, November 1 2018 , pp.241-246(6)




Review of Securities & Commodities Regulation

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Abstract: 

An increasing number of enforcement actions against CCOs for their organizations’ misconduct has focused attention on their duties and responsibilities. The authors address this subject, giving an overview of the role of CCOs, recent enforcement actions against them, and theories of liability in the cases. They close with specific actions CCOs are advised to take to mitigate such risks.

Keywords: Chief Compliance Officer (“CCO”); CCOs’ Personal Liability

Affiliations:  1: Pepper Hamilton LLP; 2: Pepper Hamilton LLP.

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