In a fraud case involving the fraudulent sale of a sham oil and gas company by registered representatives as a dually registered investment adviser/broker-dealer, the SEC charged the firm's Chief Compliance Officer (CCO) with various violations of the federal securities laws related to a cover-up of the registered representatives’ allegedly fraudulent conduct and other compliance failures. The case is instructive in identifying willful, reckless, or negligent activities and failures that may cause a CCO to be targeted in an SEC enforcement action.