Caroline Pham, a commissioner at the Commodity Futures Trading Commission, said compliance officers have a lot to worry about if they or their firms are subject to CFTC enforcement.

She also said they should not expect to receive any credit for self-reporting systemic compliance deficiencies at their companies.

Pham, as part of a fireside chat Tuesday at Compliance Week’s Financial Crimes and Regulatory Compliance Summit in New York, told a room of practitioners the regulator’s Enforcement Division will likely hold a business and its compliance function equally liable for misconduct. Said another way, chief compliance officers could be found to be just as culpable as the risk-taking side of the business for violations of CFTC rules and regulations that occurred under their watch.

It is one of the reasons, Pham said, that she never pursued the position of CCO when she worked in compliance in the financial services industry.

“I would never want to be in compliance at a CFTC registrant,” she said. Before joining the CFTC in 2022, Pham served as a managing director at Citigroup, where she worked in various senior executive roles in the chief administrative office, as well as legal, compliance, and the institutional clients group.

Pham noted the views she shared were her own and not representative of the commission or her counterparts.