Compliance officers have a lot to worry about. Do they have the right structure? Is their program effective? What will their successor say when they are gone? Did they get it right? Is the program sustainable without the compliance professional overseeing it? All chief compliance officers know that in the event of a compliance failure, regulators will second-guess their efforts. And they may take legal action against the CCO.

Last month, the U.S. Attorney’s Office in Manhattan filed a civil lawsuit against MoneyGram International Inc.’s former CCO Thomas Haider to collect a $1 million fine on behalf of the Financial Crimes Enforcement Network (FinCEN) and keep him from working for any other financial institution. U.S. Attorney Preet Bharara said: “Compliance officers perform an essential function in our society, serving as the first line of defense in the fight against fraud and money laundering . . . [and the U.S. Attorney’s Office is] committed to working with FinCEN to enforce the requirements of the Bank Secrecy Act and hold individuals such as Mr. Haider accountable.” In 2012, MoneyGram forfeited $100 million as part of a deferred prosecution agreement to resolve an investigation by the U.S. Department of Justice into money laundering; FinCEN is seeking to hold the company’s former compliance chief financially personally responsible.

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