“Operation Codebreaker” and the Culture of Compliance (Harvard Law School Forum on Corporate Governance)

Harvard Law School Forum on Corporate Governance, March 4, 2020

“Operation Codebreaker” and the Culture of Compliance

NYCBA Report. Related concerns with compliance program effectiveness are noted in the recent report from The New York City Bar Association, “Chief Compliance Officer Liability in the Financial Sector.” This detailed report identifies the unnecessary risks that financial firm compliance officers face and which serve to undermine compliance program, and compliance officer, effectiveness and related regulatory and enforcement goals.

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