CCO Compensation Up 9 Pct

Attention, all you compliance officers negotiating a new pay package! We have a fresh CCO compensation survey that says average salary and bonus are at $430,000 this year, up 9 percent from 2020 levels. 

Recruitment firm Major, Lindsey & Africa published the compensation report today. Much of the data relates to general counsels and other legal officers, but the report does include a few items about compliance officer compensation worth noting as you stare at your pay stub or that jerky boss you can’t stand. 

Within the United States, the report said, average base salary for chief compliance officers rose 8 percent from 2020 levels to $295,900. The average target bonus (that is, the potential bonus you might earn if you hit all performance goals) jumped 15 percent to $181,900 — but average actual bonus was only $172,500, a decline of 4 percent.

So when you perform the appropriate statistical wizardry to consolidate those three figures, average total cash compensation for U.S. chief compliance officers stood at $430,200 in 2022, up 9 percent from $396,300 in 2020. See Figure 1, below. (Unfortunately the report does not offer CCO compensation data for other parts of the world.)

Why the pay raise over the last two years? In its report, Major, Lindsey & Africa strokes the compliance community’s collective ego by praising CCOs as “having become critically important management team members in recent years — especially in the United States, with its complex regulatory environment and the world’s most active litigation climate.”

Sure, that’s all true. There’s also the macro-economic reality of an incredibly tight labor market for the last two years. That’s not likely to change any time soon for highly skilled labor, even if the U.S. economy teeters into recession. 

More Compensation Details

The report also provides several slices of more granular data for U.S. compliance officers, to help put your compensation package in a more accurate and precise context. For example:

• Male CCOs earned 6 percent more than female CCOs, $440,000 compared to $415,500
• White CCOs earned more compensation ($421,140) than any other ethnicity by a fair bit, and also saw the largest compensation increase (13 percent) from 2020
• Compensation for black CCOs dropped by 54 percent, but that was from a 2020 average compensation of $771,500, which might be an anomaly due to the small number of responses two years ago

We should also keep in mind that not all compliance officers hold the actual title of “chief compliance officer.” For anyone who has a legal role — deputy general counsel, assistant general counsel, senior counsel, regional counsel, and so forth — Major, Lindsey & Africa also included this chart showing average pay packages. 

As you can see the only legal role that saw a decline in compensation was the measly “counsel” role, where compensation dropped 10 percent.

Of course, CCO compensation surveys are notorious for being all over the place with their numbers. Last year recruitment firm Barker Gilmore released a report finding that CCO compensation had risen 3.5 percent over one year; in 2019, the Society of Corporate Compliance & Ethics found that compensation had risen 4.5 percent from 2017 to 2019. Both studies also reported compensation packages that were considerably lower than the $430,000 average cited here. 

That said, a 9 percent increase over two years doesn’t feel wrong, especially given the rising importance of a strong compliance function to overall corporate success. At the start of this year I flagged CCO compensation as one of the industry developments to watch for 2022 for that very reason. 

In my reckoning, SCCE publishes the most comprehensive salary reports around. It is planning a 2022 salary report later this year, and we should all stay tuned for that one.