The most successful compliance officers are those who understand the risks inherent in the position and learn to navigate the corporate power structure. Compliance officers have far more authority - the authority to investigate most any allegation - than they have power. While compliance officers are often identified as senior executives of an organization, the more likely to be found at the upper mid-management level. This creates a crisis when the compliance officer is required to investigate high level corporate wrong doing as every compliance officer eventually will. Even if the compliance officer proves the wrong-doing, they are no longer able to work in their organizations. For the compliance officer to survive and succeed, they have to establish a power base probably reaching to the level of the Board of Directors Committee charged with overseeing the compliance program. This is often very contrary to the skills which got the individual appointed as compliance officer. Some of the least successful compliance officers are attorneys appointed to the position for the simple reason that they have a law degree and with no idea how an organization actually works.
Mark Pastin, President of the Council of Ethical Organizations, and its subsidiary, Compliance Research Group, Inc.