Case study · For companies
A chief compliance officer search for a NYSE-listed payments company in New York
The audit committee wanted a CCO who had sat across a supervisor. We assessed the field against the DOJ ECCP, shortlisted in week 3, and closed in week 10.
A payments CCO is assessed against the ECCP, not against a policy binder
If the Department of Justice asked three questions of the programme, the hire had to have already lived the answers.
A NYSE-listed payments company in New York hired a Chief Compliance Officer on a retained search. The reporting line ran to the audit committee. We assessed candidates against the U.S. Department of Justice Evaluation of Corporate Compliance Programs: whether a programme is well designed, applied in good faith, and working in practice. The shortlist arrived in week 3. The accepted offer closed in week 10. The file is one of 41 compliance and regulatory leadership placements inside 230+ in-house and corporate placements since 2017.
Dual-regulated financial services companies typically run 15 to 40 lawyers plus a compliance function. This seat was not a deputy GC with a compliance title. It was the person who would sit across a supervisor and still have a job the following Monday. Talent acquisition could source "compliance leaders." It could not tell an examination from a policy rewrite. Outside counsel could advise on the programme. They could not be the programme.
- Mandate
- Chief Compliance Officer, NYSE-listed payments, New York. Audit-committee reporting line. One of 41 compliance-leadership files.
- Assessment
- Dossiers written against the DOJ Evaluation of Corporate Compliance Programs (design, good faith, working in practice).
- Shortlist
- Week 3. Programme CCO clock: 21 days to shortlist, n=41.
- Accepted offer
- Week 10. Programme CCO clock: 10 weeks to accepted offer.
- Field mapped
- Sitting CCOs and heads of compliance at dual-regulated payments and fintech companies in New York — a field in the tens.
- Terms
- Retained, 28-33% of first-year cash, three instalments, 12-month replacement.
The audit committee was the client. The GC was a stakeholder.
Payments at NYSE scale sits under a stack of supervisors. The committee's fear was not "we lack a policy." It was a finding that the programme existed on paper and died in the product release. ACC's 2025 Chief Legal Officer Survey names risk, compliance, data privacy and regulatory change as the issues CLOs rank first. That is the climate. It is not a reason to hire a policy author and call it a CCO.
The general counsel needed a peer, not a report. A CCO who reports only through the GC will lose the argument the first time a revenue product and a control collide. The committee wrote the reporting line first: audit committee, with a working line to the GC and the CEO. That sentence in the Mandate Blueprint did more than any competency framework.
Internal talent had already run a confidential process that produced three names, all policy authors from adjacent industries. None had sat through an examination. None could name the last time they had taken a resource fight to a board and won. The committee stopped that process and retained a search. Fee, replacement window and off-limits went into the letter before we called anyone. A CFO — on a different file, a London-headquartered private-credit manager — described the same gate: that is the only way they will sign a search firm. The hire on that file accepted on the first offer. So did this one.
Examinations named. Policy authorship discounted.
Supervisor time
Has sat across a US payments or banking supervisor as the accountable executive, not as note-taker.
Resource fights
Has won headcount or system spend from a board after a finding, and can show what the money did.
Independence
Will take the audit-committee line seriously when a product and a control collide.
Disqualifiers: a career spent writing policies for a consulting firm; a title of CCO over a programme of two people at an unregulated company; anyone whose last three years had no examination. Must-haves were ugly on purpose. Pretty CVs are how payments companies hire a communications function and name it compliance.
Dual-regulated financial services is a 15-40 lawyer legal bench plus compliance. The CCO was not asked to also be GC. The GC was not asked to also be CCO. That split is the search. Companies that blur it hire a generalist and wait for the finding. The service that carries this work is compliance and regulatory recruitment, including the New York city page at compliance recruitment in New York City.
New York payments compliance is a field in the tens
We mapped sitting CCOs and heads of compliance at dual-regulated payments and neighbouring fintech companies in New York. The universe is small. That is the difficulty and the advantage.
A field in the tens can be named. It cannot be posted. Everyone in it has already taken a call from someone this year. A second clumsy call is how a search becomes a rumour that the NYSE-listed payments company is "under pressure." We approached a short field, blinded, after conflicts. We do not publish exact map totals. The honest unit is the band: tens, not hundreds, not thousands.
Each dossier named examinations. Not "regulatory experience." The committee interviewed a short list. It hired one. Programme CCO searches reach a shortlist in 21 days — week 3 on this file — and an accepted offer in 10 weeks. That clock is faster than a GC/CLO median of 11 weeks because the assessment is narrower: examinations, independence, resource fights. It is not a personality contest with a legal overlay. City mapping for in-house seats in the same market sits at in-house counsel recruiting in New York City. Pay context, kept separate from this file's clock, is on chief compliance officer pay, 2026.
Week 3 shortlist. Week 10 accepted offer.
| Week | Milestone | ECCP test in the room |
|---|---|---|
| 1 | Mandate Blueprint | Audit-committee reporting line written. Fee letter signed. |
| 1-2 | Map the New York field | Sitting CCOs in dual-regulated payments — a field in the tens. |
| 2-3 | Private outreach | Blinded. Examinations named in the first serious conversation. |
| Week 3 | Shortlist | Dossiers against design / good faith / working in practice. Programme: 21 days. |
| 4-9 | Committee interviews | A live finding, a resource request, a product stop — not a case study. |
| 10 | Accepted offer | First offer. Programme CCO clock: 10 weeks, n=41. |
| 11+ | Start, 90-day check | Independence tested on the first product that collides with a control. |
Replacement on retained CCO searches is 12 months. Programme offer-acceptance on corporate mandates is 96%.
Source: Sartori & Partners corporate track record, 2017-2026 (this file; compliance leadership n=41).
Fee, replacement window and off-limits were in the letter before they called anyone. That is the only way I will sign a search firm.
Accepted on the first offer. Retention is a programme rate.
The sitting employer counter-offered with title and a retention bonus. The candidate was not moving for a bonus. They were moving for an audit-committee line and a programme they would be allowed to run. The offer was accepted in week 10, on the first letter. Across corporate mandates, 96% of offers we take to a signed letter are accepted. Retained corporate mandates complete at 92%.
We do not attach a named-client retention promise to this file. Across placed in-house leaders, 97% remain at 12 months and 91% remain at 24 months. The 90-day check on a CCO file is specific: did the first product-control collision go to the committee, or get bargained away in a legal meeting? That is the test the ECCP would recognise.
Client reference
The CFO gate on a retained search
Fee, replacement window and off-limits were in the letter before they called anyone. That is the only way I will sign a search firm. The hire accepted on the first offer.
A CCO hire is an independence hire with an examination record
- Write the reporting line before you write the competencies. Audit committee first, working line to the GC, or the seat is decorative.
- Assess against the DOJ ECCP: design, good faith, working in practice. Name examinations. Discount policy authorship.
- The New York payments compliance field is in the tens. Posting it is how you hire a rumour.
- The clock is week 3 to shortlist, week 10 to accepted offer on this file — the programme CCO clock (21 days / 10 weeks, n=41).
- Fee, 12-month replacement and 24-month off-limits belong in the letter before outreach. Retention is a programme rate (97% at 12 months), not a named-client slogan.
External documents this search used
2 referencesCCO search, next reads
Compliance and regulatory recruitment
CCO, MLRO, sanctions and privacy leadership for supervised companies.
Open compliance recruitingHow to run a general counsel search
Mandate Blueprint to 90-day check-in on the 24-day / 11-week clock.
Read the 2026 search clockLegal talent for companies
How audit committees and GCs brief a retained mandate.
Go to the companies hubCase studies
Anonymised corporate files, including this CCO search.
Browse case studiesRelated files: GC succession in Boston medtech, interim GC in San Francisco fintech, compliance officer salary, 2026, and retained versus contingency legal search. New York in-house seats sit at in-house counsel recruiting in New York City.
CCO search, NYSE payments: four questions
How do you assess a chief compliance officer against the DOJ ECCP?
You test the person against the document the Department of Justice actually uses, not against a policy author's CV. The Evaluation of Corporate Compliance Programs asks whether the programme is well designed, applied in good faith, and working in practice. Dossiers on this file named examinations sat, issues found, and resources the candidate had won from a board. See compliance and regulatory recruitment.
How long did this New York payments CCO search take?
The shortlist arrived in week 3 and the accepted offer closed in week 10. That matches the programme clock for CCO searches: 21 days to shortlist and 10 weeks to accepted offer, across 41 compliance-leadership files since 2017. The full seat-by-seat clock is in how to run a general counsel search.
Should a CCO report to the audit committee or to the general counsel?
On this file the reporting line ran to the audit committee, with a working line to the GC. Dual-regulated payments companies cannot treat compliance as a legal sub-function that the GC can overrule in a deal. The committee wanted a CCO who had sat across a supervisor, not a policy author. ACC's 2025 Chief Legal Officer Survey still ranks risk, compliance and regulatory change as top CLO concerns — which is why the seat is independent.
What commercial terms apply to a retained CCO search?
Retained CCO searches use a fixed fee of 28-33% of first-year cash, three instalments, and a 12-month replacement window. Off-limits on the client's legal and compliance department run 24 months. Fee, replacement and off-limits go in the letter before outreach. A CFO put it plainly: that is the only way they will sign a search firm. Detail sits in legal recruitment fees explained.
Start a CCO search
If the audit committee wants examinations named, do not run a policy-author process.
We will put the ECCP in the scorecard and the fee in the letter before we call anyone. Week-3 shortlist is the programme CCO clock.