Report: CCO Compensation Up 8 Percent

Who doesn’t love a good compliance officer salary survey? Recruiting firm Barker Gilmore just published its 2023 report, finding that average total compensation for compliance officers is running about $320,000 these days, up 8 percent from last year’s figures.

Barker Gilmore published its report earlier this week, based on a survey of 500 compliance professionals — a blend of chief compliance officers and lower-level compliance executives, at both public and private companies. The report also offers comparisons between genders, those who have law degrees versus those who don’t, and even a breakdown of compensation depending on how many direct reports you have. So if you’re looking for a raise or want a better sense of whether your next potential employer is low-balling you, the Barker Gilmore report is well worth your time.

Let’s begin with the whole group. Total compensation for all compliance professionals who responded to the survey rose 8 percent, to an average of $320,000 — but as happens so often in life, the more senior compliance executives saw larger pay increases than the peons. See Figure 1, below.

Source: Barker Gilmore

The report also tracked average total compensation across seven industries. The sector with the biggest gain was industrial manufacturing, up 7 percent; with the consumer and technology sectors close behind at 6 percent. Even all the other sectors, however, saw average compensation increase at least 4 percent. That’s not quite enough to keep pace with the nosebleed inflation we all saw in 2022, but it’s not chump change either. 

Another interesting factoid: most compliance officers said their job searches are not primarily motivated by wanting to make more money; see Figure 2, below. 

Source: Barker Gilmore

That feels right to me. My theory (with no empirical evidence to support it, but based on years of experience and observation) is that most compliance officers already make good money, so they’re not in dire need of more. Of course, more money is always nice, but the primary complaints I hear from compliance officers are about bad bosses, lack of promotion opportunities, or corporate bureaucracies that drive them crazy. Those are the things that make compliance officers decamp for greener pastures.

The Value of Legal Experience

Barker Gilmore also found that compliance professionals with a JD tend to make more,  and sometimes considerably more, than their peers who don’t have a JD. 

For example, chief compliance officers at publicly traded companies who had a JD had average total compensation of $588,000 last year. For CCOs without a JD, average total compensation was only $348,000. Lower-level compliance officers at public companies saw a similar gap: average total compensation of $347,000 for those with a JD, versus $242,000 for those without.

Moreover, that salary premium for having a JD also hinges on which law school you attended, and whether you worked at a prestige law firm. For example, all compliance officers with JDs make more than those without one (about 15 percent more, according to Barker Gilmore) — but that spread widens to 56 percent for those who attended a top 50 law school. Likewise, compliance officers with law firm experience had average total compensation about 25 percent larger than compliance officers with no firm experience; but among those who worked at a top 50 law firm, the gap was 62 percent more. See Figure 3, below.

Source: Barker Gilmore

These statistics intrigue me because for many years people have debated whether you really need a law degree for a successful compliance career. I say no; I’ve met plenty of compliance leaders over the years who’ve done great things and had solid careers without one. 

On the other hand, this salary survey suggests that a compensation premium does exist for compliance officers with a JD and law firm experience. So what does a mid-career professional do, when he or she discovers that they have a passion for compliance but there’s no earthly way they’re going to step aside from the workforce for three years and drop at least $100,000 for a JD? 

Can you bridge the difference with one of those master’s in legal and compliance studies that so many law schools offer now? Or maybe one of the many compliance certifications offered by the Society of Corporate Compliance & Ethics and other groups? 

Are We Compensating Here?

I dwell on this issue so much because if boards, CEOs, and general counsels fixate on the idea that chief compliance officers must have JDs, eventually that’s going to act as a brake on the career development for legions of budding compliance officers. 

After all, as I noted earlier, most people who go to law school do so relatively early in life. If the hiring gods then tell everyone over 35, “Oh, sorry, you missed your window to get a JD so you’ll never rise to the top of this profession” — that strikes me as tremendously counter-productive, and a disservice to all the great compliance thinkers out there who didn’t have the foresight to take the LSAT at age 22. 

I understand that the great JD debate has many nuances, and obviously those people who attend top schools and work at the most rigorous law firms tend to be smarter and therefore earn more money. Still, there are plenty of other smart, industrious people out there who can bring fantastic skills to the ethics and compliance profession, even (and probably especially) at the leadership level. 

I hope Corporate America is smart enough not to keep those people trapped underneath yet another glass ceiling. The world has enough of those already.

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