If you want to charge CCOs in ‘wholesale’ compliance failures, parse out level of resources, participation, cooperation, obstruction: NYC Bar Association says in proposed enforcement framework

The Skinny: A powerful legal body in the heart of Gotham has calibrated the elements of individual liability for top compliance leaders in high-profile program failures, a move done to temper the rising fears of a community of professionals responsible for decisions and actions largely out of their control. The New York City Bar Association […]