Who is Responsible for Corporate Misconduct?

A Dialogue with an SEC Commissioner: Liability for Corporate Misconduct: Directors, C-Suites, Chief Compliance Officers

SEC Commissioner Hester Peirce participated in a Q&A session to discuss issues important to business leaders and the Bar regarding corporate and personal compliance duties and liabilities. Following the Q&A, a distinguished panel explored some of the issues raised such as:

  • Preventing misconduct before it occurs.
  • Ensuring sufficient resources and a culture of compliance.
  • The role of risk management in translating legal advice into compliance policies and operations.
  • Regulatory and law enforcement treatment of the company and its leadership.
  • Who should be held responsible for failure?

Speakers:

Hon. Hester Pierce, Commissioner, U.S. Securities and Exchange Commission

Alma Angotti, Partner, Financial Services Global Legislative and Regulatory Risk Lead

Elizabeth Gray, Willkie Farr & Gallagher LLP

Joseph (Jody) Myers, Chief Risk Officer, Western Union Company

Leo Tsao, Deputy Chief, Money Laundering and Asset Recovery Section (MLARS) Criminal Division, US Department of Justice

Clark Abrams (Moderator), Chief Money Laundering and Financial Investigations Unit, Office of the Special Narcotics Prosecutor, City of New York

The compliance personnel at the firms, many of whom have spent time at the SEC really are partners with us in the firms. They're working towards the same objectives, which is is help their firms comply with the rules.

Hon. Hester Peirce, Commissioner, U.S. Securities and Exchange Commission

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