CCO Compensation Update

We haven’t taken a look at compliance officer compensation in a while, so today let’s revisit that always-popular subject — especially since a new salary survey found that lots of chief compliance officers are making gobs of money. 

That survey comes from recruitment firm Barker Gilmore, which several weeks ago published its 2024 General Counsel and Chief Compliance Officer Compensation Report. BarkerGilmore polled 382 in-house compliance and legal professionals across a range of industries to see what they are getting paid this year.

The big finding is that average salary for all chief compliance officers is holding steady in 2024 compared to last year. Certain groups within the whole CCO population, however, are enjoying big jumps in annual bonus payments and long-term incentives, so total compensation for those groups is surging — all the way up to $918,000 at the highest end!

Figure 1, below, tells the tale. Salary bands are organized by percentile: 25th, 50th, 75th, and 90th.

As you can see, companies with less than $500 million in annual revenue pay less in salary, bonus, and long-term incentive (LTI) for almost all salary bands. Total compensation for those at smaller companies is also lower when compared to larger peers within the same salary band, although the best-paying small companies do offer more than the worst-paying larger ones. 

Most astonishing, however, are the large companies at the highest salary band. They report an average salary of $387,000, average bonus of $167,000, and average LTI of $364,000. That adds up to $918,000 in total compensation, a number I just can’t believe.

(“Who are these compliance officers making $920,000?” one flabbergasted compliance professional asked me upon reading the survey results. “And are they single?”)

Unfortunately BarkerGilmore presented somewhat different data in its 2023 report, so we can’t easily compare this year’s salary-banded results to last year’s. That 2023 report, however, did find that average total compensation for all CCOs was $320,000, up 8 percent from 2022 numbers.

Salary vs. Other Compensation

Despite those hefty numbers, all you readers grumbling that your paycheck hasn’t gotten any larger do have reason to complain. The BarkerGilmore report found that average salary for mid-sized and large companies stayed flat in 2024, although average salary for CCOs at smaller companies rose 4 percent. 

On the other hand, the size of target bonus jumped sharply for all companies, as seen in Figure 2, below.

So are compliance officers satisfied with this level of compensation? 

Apparently not, according to the survey. Half of chief compliance officer respondents said there is a “high” or “very high” chance that they will look for another job in the coming year specifically because they want better compensation, compared to only 37 percent who said that in last year’s survey. 

If you’d like to speculate about why that’s so, I will merely note that the general counsels surveyed by BarkerGilmore saw truly staggering increases in their total compensation this year, fueled by LTI compensation that often ran into the millions. (Mostly thanks to Wall Street’s killer performance from 2021 until, like, last Friday and today.) 

The chief compliance officer job is tough and often thankless, and at many companies it’s also one step away from top legal roles where you stand to make oodles more money. Given those dynamics, why wouldn’t a disgruntled compliance officer look for brighter pastures?

Other Odds and Ends

One bit of good news is that 55 percent of CCO respondents said they report directly to the CEO, versus only 40 percent who report to the general counsel. This continues a long, slow trend of CCOs no longer reporting into the legal department, which is as God and the Framers of the Constitution intended; although we need to emphasize “long” and “slow” here. I remember one CCO industry survey I compiled more than 10 years ago where only 38 percent of CCOs reported to the CEO. So we’re moving in the right direction, but it’s baby steps all the way.

Lastly, while compliance officers can peruse the BarkerGilmore report at their leisure and find numerous useful insights, the gold standard for compliance officer compensation data remains the Society of Corporate Compliance & Ethics, which publishes an in-depth report every other year. The most recent SCCE salary survey came out in 2022, and my sources tell me its 2024 report is on track to be published later this fall. Radical Compliance will have complete coverage of that report too in our endless mission to help you make more money.