The role of any chief compliance officer is multi-faceted. In the investment management space, responsibilities include ensuring all investment activities are in compliance with applicable regulations to engaging with financial regulators to answer questions and address concerns. While the exact regulatory and cultural changes that may roll out under the new leadership of the Securities and Exchange Commission remain uncertain, the list of responsibilities and critical function of a CCO to an investment adviser are always evolving. In this article published in the April 2021 issue of National Law Journal, Silver’s CEO, Fizza Khan, illustrates a recent case in which the SEC held a CCO of an investment adviser personally liable for lack of supervision and engaging in fraudulent activities, and outlines areas in which CCOs should pay careful attention to lower their risk of potential liability.
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