NSCP Currents CCO Liability Framework Article Wins Law360 Distinguished Legal Writing Award
Eversheds Sutherland attorneys Brian Rubin and Amy Albanese have been recognized with the “Law360 Distinguished Legal Writing Award” for their article “A Tale of Two Enforcement Actions Against Compliance Officers: An analysis applying the NSCP Firm and CCO Liability Framework.” The article was originally published in the March 2022 issue of NSCP Currents, the premier compliance publication of the financial services industry.
On January 10, 2022, NSCP issued its “Firm and CCO Liability Framework” to “more effectively address the issue of CCO liability.” The Framework focuses on “the larger context of the compliance function within firms,” evaluating real world issues such as whether the compliance officer had actual responsibilities to affect conduct and the resources to do the job. In the article, Rubin and Albanese use the Framework to see how it might affect two recent compliance officer enforcement actions, one brought by the SEC and one brought by FINRA. Where the relevant facts are unknown, they present hypothetical “yes” and “no” answers to show the possible effect.
Selected from nominations submitted by the nation’s 1,000 largest law firms, the honor will be presented at an awards reception in June held in association with the Library of Congress, presented by Law360 and co-sponsored by the ABA.
