The SEC censured and fined an investment adviser for failing to supervise one of its employees who engaged in an unauthorized cherry-picking scheme. Although the adviser had procedures requiring preclearance of personal trades, the SEC asserts that the firm failed to implement the preclearance procedures even after a third party consulting firm notified the firm of its failures to implement. As part of the settlement, the adviser will deliver the order to each of the affected clients.
When you hire a compliance consultant, you should not ignore their recommendations. The SEC will likely assert that you have displayed an unwillingness to implement a legitimate compliance program.