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 coverup of the registered representatives’ allegedly fraudulent conduct and other compliance failures. caused them to be targeted. 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.