The SEC expects investment advisers to take their compliance duties seriously and to employ experienced compliance personnel. In a recently settled enforcement proceeding, someone who allegedly had no prior securities industry experience walked into a minefield when she became CCO of an improperly registered adviser, which for several years had been overbilling a client and making material misstatements in its marketing materials and disclosures. The SEC came down hard on the adviser, its founder and the CCO. This article details the SEC’s allegations and the terms of the settlement, with commentary from Andrew M. Calamari, partner at Finn Dixon & Herling and former Regional Director of the SEC’s New York office. See “SEC Fines and Bars CCO From the Funds Industry for Compliance Failures and Deceiving Examiners” (Mar. 11, 2021); and “How CCOs Can Avoid Personal Liability for Organizations’ Compliance Failures” (Mar. 11, 2021). See also our two-part series on the NYC Bar framework for CCO liability: “Components and Proposals” (Jul. 15, 2021); and “CCO and Regulator Perspectives” (Jul. 22, 2021).