Last month, SEC Enforcement Director Gurbir Grewal gave a speech at the New York City Bar Association’s Compliance Institute addressing chief compliance officer liability. While the speech likely provided some comfort to CCOs, unfortunately, it raised more questions than answers, such as:

• Are compliance officers on the front line?
• Are compliance officers responsible for implementing and executing policies and procedures, or is their function to provide advice?
• Do compliance officers need to become experts of “everything everywhere all at once” at their firms?
• What is a “wholesale failure” to carry out compliance responsibilities?

Eversheds Sutherland Partners Brian Rubin and Adam Pollet share their thoughts here on these questions, as well as information about what the SEC and FINRA could use in future cases brought against CCOs  .