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The Yates Memo: The DOJ Gets Personal

  • Did you know that failure to act – even without intent of wrongdoing, is now enough to warrant prosecution of a Chief Compliance Officer?
  • Did you know that one of three violations specified by the SEC in a case involving a Chief Compliance Officer was failure to conduct an annual review of its compliance program?
  • Did you know another Chief Compliance Officer was fined $60,000, personally, in part for failure to recommend written policies and procedures to support an existing Conflict of Interest Policy?
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