The issue of chief compliance officer (CCO) liability has long been debated; it has become a grave concern for CCOs, CEOs, and other C-suite executives who put on “too many hats” within an organization and take on the firm’s compliance responsibilities. In fact, according to a survey completed by the Wall Street Journal in 2022 (Figure 1), the risk of regulatory scrutiny increased for compliance officers last year by 72%, with cybersecurity topping the charts for the greatest risk (86% increase in 2022) followed by privacy issues (73% increase).[1]

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By Fizza Khan and Jessica Thayer