Navigating CCO Liability Risks: Tips for Staying Out of the SEC’s Crosshairs

CCO liability remains top of mind for C-Suite executives, particularly in today’s heightened regulatory environment. Silver’s CEO, Fizza Khan, co-authored a byline in CEP Magazine with Jessica Thayer, Senior Vice President at Starkweather & Shepley Insurance, that offers tips on how CCOs can stay out of the SEC’s crosshairs.

Copyright 2023 CEP Magazine, a publication of the Society of Corporate Compliance and Ethics (SCCE).

The issue of chief compliance officer (CCO) liability has become a matter of grave concern for CCOs, CEOs and other C-suite executives that put on “too many hats” within an organization and take on the firm’s compliance responsibilities.

In the June issue of CEP Magazine, a publication of the Society of Corporate Compliance and Ethics (SCCE), Silver’s CEO, Fizza Khan, co-authored a byline with Jessica Thayer, Senior Vice President at Starkweather & Shepley Insurance, that offers tips on how CCOs can stay out of the SEC’s crosshairs. Below are key takeaways from the article:

  • As regulators work to formalize guidance for chief compliance officers (CCOs) on the scope of their responsibilities and limitations around personal liability, now is the time for firms to better understand the extent of individual liability for compliance officers when determining potential compliance failures.
  • CCO liability can be a complex yet nebulous concept to navigate. Therefore, it’s important to understand how CCO liability is being defined by regulating bodies.
  • Mitigating the risks of CCO liability hinges on understanding the types of cases out there that triggered regulatory enforcement actions. Therefore, certain top matters elucidating the potential dangers of CCO liability are highlighted.
  • Understanding CCO liabilities, the regulatory landscape and examples of “bad behavior” are important steps in protecting CCOs against potential risks, especially with so much on the line for CCOs.
  • CCOs can be held personally liable for any compliance failure, which can lead to significant legal and financial consequences and overall reputational harm for both the firm and the CCO.

Download the full article here

Share the Post:

SilverVision Archive

2026 PRI Reporting Guide

PRI’s 2026 Transparency Reporting season is fast approaching, and for many Signatories, this year’s process will look very different from prior cycles. With a significantly revised framework, fewer indicators, and new mandatory requirements, now is the time to understand what has changed before the reporting window opens on May 6 and closes on July 29.

Read More »

Regulation S-P Amendments Shift the Compliance and Cybersecurity Landscape: What the Amendments Mean and How Firms Can Navigate Them

The SEC’s amendments to Regulation S-P (Reg S-P) reflect heightened expectations for how financial firms protect customer information, respond to incidents, and oversee service providers. With tighter notification timelines and more explicit documentation requirements, the amendments serve to remind investment advisers that compliance and cybersecurity are operational priorities.

Read More »

Fizza’s Guide to What’s Inside – Q1 2026

Q1 2026 has been a reminder that for private fund managers, regulatory change is not slowing down and neither are the expectations that come with it. In the upcoming edition of Silver’s Regulatory Recap, we are focusing on several developments that we believe are especially important to have on your radar right now.

Read More »

2025 Sustainability Regulation Recap: The Updates That Matter and How to Prepare for 2026

The past few years have produced a seemingly unending deluge of changes and updates to sustainability regulations and standards, and 2025 was no different. In this article, Silver’s Sustainability Risk & Strategy team summarizes all the activity from 2025 and provides key items investment managers need to be aware of, along with practical steps for addressing these changes in 2026.

Read More »

Navigating the SEC’s 2026 Exam Priorities

The SEC’s 2026 Examination Priorities signal tighter scrutiny for private fund advisers, with expectations increasingly tied to real-world risk and demonstrable controls. Silver breaks down the 2026 focus areas with lessons from 2025 exams and outlines three practical actions firms can take now to strengthen exam readiness.

Read More »