The SEC's case against Buckingham and its chief compliance officer on Wednesday highlights the basic rule that "you can't have just paper policies," says Deborah Meshulam, chair of the securities-enforcement practice at DLA Piper who formerly served as an assistant chief litigation counsel in the SEC's Enforcement Division. "You have to have the right policy and enforce that policy," she says.

An interest among regulators in gatekeepers, such as chief financial officers and chief compliance officers, is another reason to do the job right, says Meshulam. "Anyone with those responsibilities really has to pay attention," she says.

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