SEC’s Grewal Details ‘Rare’ Conditions For CCO Liability (Law360)
Law360, October 24, 2023
SEC’s Grewal Details ‘Rare’ Conditions For CCO Liability
Speaking at the New York City Bar’s Compliance Institute, Gurbir Grewal said the commission will typically bring enforcement actions against compliance personnel in three scenarios — when they affirmatively participate in misconduct unrelated to compliance, mislead regulators or have a ‘wholesale failure’ in carrying out their compliance responsibilities.