How CCO Framework Could Have Altered FINRA Charges

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By Brian Rubin (February 25, 2022, 4:40 PM EST) — Every year, the Financial Industry Regulatory Authority brings hundreds of cases, many alleging that firms have inadequate policies and procedures.[1]

In the overwhelming majority of those cases, the chief compliance officer, who FINRA considers to be “a primary advisor to the member on its overall compliance scheme and the particularized rules, policies and procedures that the member adopts,”[2] is not charged.

With regard to anti-money laundering cases, AML compliance officers are also infrequently charged.

For example, since January 2021, FINRA has brought 12 AML cases against firms, but charged only two AML compliance officers.[3]

Questions that always follow such cases include: When are…

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