Since mid-2010, Brian L. Rubin & Katherine L. Kelly of Sutherland Asbill and Brennan, LLP have been publishing periodic updates covering SEC and FINRA disciplinary actions taken against chief compliance of?cers for broker-dealers or investment advisers. Their latest update, covering SEC and FINRA actions between November 2010 and June 2011, collects cases against CCOs for conduct including:

playing a role in their respective firms' inadequate due diligence of private placement products;

failing to supervise registered representatives;

aiding and abetting their firms' underlying violations;

permitting an unregistered individual to trade securities;

failing to preserve emails; and

failing to provide anti-money laundering supervision

The title of the article ("The Girl with the SEC/FINRA Tattoo: Disciplinary Actions Taken Against 

Chief Compliance Of?cers") is borrowed from Stieg Larsson's The Girl With the Dragon Tattoo, and the authors tie regulators' recent activity back to quotes from the book. They conclude that

Unfortunately for CCOs and other registered persons, once they have a “mark” on their Forms U4 or U5, those marks generally cannot be removed by laser or otherwise. The goal of any CCO is to avoid getting that mark or tattoo while, at the same time, providing advice and guidance so that a firm can grow and prosper....

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