The SEC charged a compliance officer with securities fraud and aiding and abetting his employer’s violations by “adding an aura of legitimacy” to an oil and gas offering fraud. The SEC accuses the compliance officer with ignoring misstatements in offering documents and client communications and with failing to conduct required investor eligibility due diligence. The SEC also charges the compliance officer with filing false Form Ds with the Commission.
OUR TAKE: This is what we call “voodoo compliance” i.e. using purported compliance as a tool to further securities law violations. The SEC has become wise to firms that implement sham compliance programs.