A chief compliance officer (CCO) is the person given senior responsibility for administering or overseeing an organization’s compliance program. The title does not have one universal job description: the CCO’s duties depend on the organization, its operating model, and the laws and regulations that apply to it.
What does a chief compliance officer do?
A CCO helps an organization build and operate processes for meeting its legal and regulatory obligations. Typical responsibilities include:
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- Administering written compliance policies and procedures.
- Understanding the organization’s operations and the compliance risks they create.
- Monitoring whether required controls are in place and working.
- Advising management and employees about applicable obligations.
- Receiving or identifying reports of potential noncompliance, escalating concerns, and helping ensure issues are addressed.
The precise duties are not the same at every organization. They may be shaped by the applicable legal regime, the organization’s size, its structure, and the responsibilities assigned to the CCO. The U.S. Securities and Exchange Commission (SEC) and Commodity Futures Trading Commission (CFTC) rules illustrate requirements for particular regulated entities; they are not definitions that apply to every CCO. SEC Rule 206(4)-7 CFTC Regulation 17 CFR 3.3
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SEC-registered investment advisers
Under SEC Rule 206(4)-7, a registered investment adviser must adopt written policies and procedures reasonably designed to prevent violations of the relevant securities laws, review their adequacy and implementation effectiveness at least annually, and designate an individual responsible for administering them. These are requirements for covered advisers, not every company that appoints a CCO. SEC Rule 206(4)-7
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Registered investment companies
SEC Rule 38a-1 includes additional board oversight provisions for registered investment companies, including board approval of the CCO’s designation and compensation and an annual written report. These requirements apply to the covered funds, not to organizations generally. SEC Rule 38a-1
Certain CFTC registrants
For futures commission merchants, swap dealers, and major swap participants, CFTC Regulation 17 CFR 3.3 describes duties that include administering required policies and procedures, taking reasonable steps to ensure compliance, addressing material conflicts of interest, establishing remediation processes, and preparing an annual report. The rule’s scope is limited to those covered registrants. CFTC Regulation 17 CFR 3.3
Who should a CCO report to?
There is no single reporting line that fits every organization. SEC staff guidance says the appropriate arrangement depends on factors such as organizational size, leadership structure, the CCO’s experience, and compliance culture; it recommends at least a direct line to senior management. Rules for particular regulated entities may specify more. SEC staff guidance on the role of the CCO
For a CCO to carry out assigned responsibilities, the role also needs practical authority and support. SEC staff highlights seniority, access to leadership, adequate staffing, training, automated systems, early involvement in business decisions, and management support. The Department of Justice’s (DOJ) September 2024 Evaluation of Corporate Compliance Programs likewise asks prosecutors to consider the function’s reporting position, stature, independence, qualifications, access, and resources. The DOJ framework is an evaluation tool, not a universal job specification.
SEC Division of Investment Management Director Dalia Blass put the importance of organizational backing plainly in 2020: “Without the support of management, no CCO, no matter how diligent and capable, can be effective.” Dalia Blass, 2020
Does the CCO personally own every compliance failure?
No. The CCO title alone does not make its holder the supervisor of every employee or personally responsible for every organizational failure. In the specific SEC adviser and fund context, the SEC’s December 17, 2003 adopting release states that appointment under the compliance rules does not itself confer supervisory responsibilities. Separate supervisory duties can affect the analysis, and this SEC statement is not a general ruling on liability in every jurisdiction. SEC adopting release, December 17, 2003
Compliance is an organizational responsibility. Leadership must support the function, provide appropriate authority and resources, and respond when concerns are raised; the CCO does not replace management, business controls, or adequate staffing. The DOJ evaluates how the company structures and resources compliance and how it responds to issues, rather than treating the existence of a CCO title as the whole program. DOJ Evaluation of Corporate Compliance Programs
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How to assess a CCO role
When comparing roles or evaluating whether a position is equipped to work, look beyond the title. Consider:
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- Applicable rules and entity type: Which legal regime applies, and what formal duties does it assign?
- Scope: Which policies, operations, risks, and business units are within the CCO’s remit?
- Reporting and access: Can the CCO reach senior leadership and, where relevant, the board?
- Standing and independence: Does the role have enough seniority and freedom to raise concerns?
- Capacity: Are staffing, training, and systems adequate for the assigned work?
- Ability to act: Can the CCO escalate issues and help drive remediation?
These factors reflect themes in SEC staff guidance and the DOJ’s corporate compliance evaluation framework. Their weight and formal requirements vary with the organization and applicable rules. SEC staff guidance DOJ Evaluation of Corporate Compliance Programs
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