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FCPA Blog Daily News

« Canada‚Äôs new DPA regime comes into focus | Main | Job: Chief Compliance Officer, International »
Monday
Feb112019

Compliance salaries rise. Is that a good thing?

In a January article in the French financial newspaper Les Echos, entitled “Salaries: compliance can pay big,” journalist Delphine Iweins reported that according to a 2019 compliance compensation study by the French firm Atorus Executive, 35 percent of the responding enterprises are now confident in legal compliance officer and compliance manager positions.

According to Iweins, the Atorus survey reports that 47 percent of compliance officers, whether trained in finance or law (such as a master's degree in business law), have more than seven years’ experience. The survey also reports on compliance salary ranges:

  • More than 50 percent of compliance professionals receive more than €70,000 ($80,000) gross per year.
  • A compliance lawyer with five to ten years of professional experience can expect between €55,000 and €80,000 ($62,000 and $91,000) gross per year, up to more than €110,000 ($125,000) per year after ten years -- a salary similar to that of a legal director, according to the French Association of Corporate Lawyers (AFJE).
  • A compliance manager, if he or she leads a team, will average between €120,000 and €150,000 ($136,000 and $170,000) gross per year.

Iweins goes on to note that the "exponential evolution" of these compensations "can be particularly explained" by the risks borne by the compliance function, adding, "Across the Atlantic, some compliance officers have been prosecuted by the U.S. Department of Justice in anti-corruption investigations."

Readers of Iweins’ article should take note of its subcaption: "La mise en conformité est-elle un nouvel Eldorado?" ("Is compliance the new El Dorado?").

Lawyers or businesspeople who may be tempted by the promise of lucrative compliance positions must remember that El Dorado was a mythical place of vast wealth that led many Europeans to engage in fruitless, even fatal, searches for its treasure.

Compliance work can be immensely challenging and professionally rewarding, and the indications in the Les Echos article that French companies are offering better compensation to compliance officers and specialists is an encouraging sign for the future of corporate compliance in France. But the success of any corporate compliance officer is directly dependent on the willingness of senior management to provide appropriate autonomy, resources, and support for the compliance function.

Unfortunately, many companies may be offering higher salaries for compliance officers, without understanding the need for such sustained autonomy and support or even the risks inherent in their corporate cultures.

A subsequent Les Echos article by Iweins pointedly asks, "Lutte anti-corruption: où en sont les entreprises?" ("Anti-corruption fight: Where are the companies?"), and cites a 2018 global survey by White & Case that reported that 60 percent of respondents said they would use corruption to fulfill their business goals, 19 percent said their company does not have an anti-corruption policy, and 10 percent said they do not even know whether such a policy exists.

No matter how lucrative the position, then, any compliance officer who attempts to perform his or her duties without sufficient senior-management support and resources, or who cuts corners or overlooks warning signs to accommodate business demands, may find that the road to El Dorado has become the road to perdition.

_____

Jonathan J. Rusch, pictured above, is Principal of DTG Risk & Compliance, and former Head of Anti-Bribery & Corruption Governance at Wells Fargo. The views expressed are his own. He can be contacted here