The Securities and Exchange Commission (SEC) and the Financial Industry Regulatory Authority (FINRA) seem to be focusing recent efforts on governmentally sanctioning Chief Compliance Officers (CCOs) for compliance failures in the anti-corruption arena. Last year, the SEC issued two enforcement actions against CCOs in the financial services section, and this week, FINRA announced a disciplinary action against Linda Busby, former Raymond James CCO. As a result of the action, Busby agreed to leave the industry for three years and pay a fine of $25,000. She has been the CCO from 2002 until 2013. FINRA’s enforcement chief Brad Bennett said “Raymond James had significant systemic AML failures over an extended period of time, even when the firm was previously sanctioned in the area.
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