Jeremy Vaughan is a Partner at HighCamp. Based in Dallas, he joined the firm in July of 2023.
Tell us about your background prior to joining HighCamp.
My compliance journey started at FINRA, where I was a Senior Compliance Examiner. This role gave me my first exposure to the complexities of financial regulation, particularly in uncovering fraudulent activities and assessing firms’ internal controls. One of my first assignments was assisting with the Stanford ponzi scheme. Our investigations resulted in industry bars for numerous registered representatives for their part in the offer and sale of fraudulent certificates of deposits. This was an eye-opening experience for me, which reinforced the importance of strong compliance program and ethical business practices.
From there, I moved to the SEC, where after spending the first few years in the Ft. Worth Regional Office, I was fortunate to be selected for the Commission’s Private Funds Unit, a specialized group focused on examining the largest and most sophisticated private fund managers, which became one of the most rewarding chapters of my career. While in the PFU, I led a national initiative focused on real estate fund advisers with affiliate special servicing platforms—an experience that gave me a unique perspective on industry best practices and regulatory expectations.
After five years at the SEC, I transitioned into the private sector as a Senior Principal Consultant at ACA Compliance Group. This was a major shift for me, moving from a regulatory role into a client-facing advisory position. I worked closely with private fund managers, helping them navigate SEC regulations, preparing for exams, and implementing best-in-class compliance programs. One of the most fulfilling aspects of this role was building relationships with senior compliance professionals at some of the largest private equity and real estate firms.
In 2018, I joined Starwood Property Trust (NYSE: STWD) as Chief Compliance Officer for its newly formed SEC-registered investment adviser. Being part of the adviser’s formation from the ground up was an incredible learning experience. I led the SEC registration process, built out compliance policies and procedures, and developed a risk-based compliance testing program. Over time, the platform grew to manage approximately $6 billion in assets across a variety of investment strategies, including real estate lending, CMBS investing, infrastructure, and affordable housing private funds. In this role, I worked closely with senior leadership across different business units, which deepened my understanding of operational risk and strategic decision-making.
How have your experiences as a regulator, an in-house Chief Compliance Officer, and a consultant shaped your perspective and approach to compliance?
Having worked as a regulator, in-house as a Chief Compliance Officer, and as a consultant to CCOs, I’ve experienced firsthand how compliance functions operate from different vantage points. Each role has provided unique challenges and learning opportunities, and transitioning between them has given me a well-rounded perspective on regulatory expectations, business needs, and the practical realities of the compliance function.
Working as a regulator—first at FINRA and then at the SEC—gave me deep exposure to regulatory frameworks and enforcement priorities. As an examiner, I was focused on identifying risks, assessing firms’ controls, and ensuring compliance with federal securities laws. The work was highly investigative and analytical, and it taught me how regulators think, what red flags they look for, and how enforcement actions unfold. One of the biggest takeaways from my time as a regulator was understanding the ‘why’ behind compliance requirements—why certain rules exist, why regulators focus on specific risks, and how firms can proactively address those concerns.
Moving in-house as a CCO was a significant transition. Instead of assessing firms from the outside, I was responsible for building, implementing, and managing a compliance program from within. I had to balance regulatory expectations with business objectives, ensuring that compliance was both effective and operationally feasible. The biggest challenge—and the most rewarding aspect—was integrating compliance into the broader business strategy. I worked closely with investment teams, finance, investor relations, and legal, making sure compliance wasn’t just a ‘check-the-box’ function but a real value-add to the organization. Being in-house also required me to be more proactive in risk management, anticipating regulatory changes, and preparing the firm accordingly.
Now, as a consultant advising CCOs, I have the benefit of drawing from both my regulatory and in-house experience to help firms navigate compliance challenges. The role is dynamic because I work with a variety of firms—each with unique structures, risks, and regulatory concerns. What I enjoy most is the ability to provide strategic guidance, helping CCOs not only address regulatory requirements but also enhance their programs in a way that supports their firm’s broader goals. Unlike my in-house role, where I focused solely on one firm’s compliance program, I now have a broader view across the industry, allowing me to identify trends, benchmark best practices, and provide insights that help clients stay ahead of regulatory developments.
Each of these roles have contributed to my understanding of the bigger picture. They’ve shaped how I approach compliance, the importance of risk mitigation, and how organizations can not only meet regulatory requirements but use compliance as a strategic advantage. All of this has naturally culminated in my current role at HighCamp, where I’m able to bring these learnings together to help our clients grow and succeed in an ever-changing regulatory environment.
What do you enjoy most about working at HighCamp?
First and foremost, it would be my colleagues! Every day, I get to work alongside incredibly talented professionals who bring a wealth of experience and unique perspectives to the table. There’s a real culture of innovation and problem-solving here, where we’re constantly thinking ahead and finding creative ways to navigate the complexities of the regulatory compliance space.
I also love the entrepreneurial spirit at HighCamp. Having worked in both regulatory and in-house roles, I appreciate the agility and forward-thinking mindset that defines our approach. We’re not just reacting to regulatory changes—we’re anticipating them and helping our clients stay ahead. That level of strategic thinking makes the work both intellectually stimulating and rewarding.
Most importantly, there’s a strong sense of purpose in what we do. We’re helping CCOs and investment professionals build stronger, more resilient compliance programs that ultimately contribute to their long-term success. Being in a position to provide real value and make a tangible impact is what makes working at HighCamp so fulfilling.
