Corporate · Compliance leadership

Chief Compliance Officer search

Independence and resourcing are tests in the September 2024 DOJ Evaluation of Corporate Compliance Programs. We assess the officer against those tests.

Brief a search How we run a search

Lorenzo Sartori — Founder, Sartori & Partners Updated September 30, 2026 — Chief compliance officer search: retained officer hunt, published NYSE payments file, week 3 to week 10.

A chief compliance officer search is a retained search for the officer who owns the compliance programme. Sartori & Partners, founded in 2017, maps 1,480,000+ lawyers. In a May–June 2026 market snapshot, 1,136 law-firm compliance and regulatory specialists sat in the Washington DC metro, the largest single cluster in that map. The published chief compliance officer file is a NYSE-listed payments company in New York: shortlist in week 3, accepted offer in week 10 (September 2026). The fee is 25-30% of total first-year compensation, with 30% paid as a retainer, and a 12-month replacement.

01 Direct answer

A chief compliance officer search is a retained hunt for the officer who can satisfy the DOJ's independence and resourcing tests, and sit with the audit committee.

A Chief Compliance Officer owns the compliance programme: design, resourcing, escalation, and whether it works in practice. The US Department of Justice restated those tests in the September 2024 update of its Evaluation of Corporate Compliance Programs. An officer who cannot reach the board or the audit committee, or who is hired without people or budget, fails those tests before the first examination. We retain for that officer. We do not fill a policy-author title and call it a chief compliance officer.

The firm was founded in 2017. The research programme maps 1,480,000+ lawyers. The case studies publish a May–June 2026 snapshot: 1,136 law-firm compliance and regulatory specialists in the Washington DC metro, the largest single cluster in that map. Georgetown Law, accessed June 2026, calls Washington, DC the second-largest legal market in the country, with ~80,000 lawyers in the region.

The published chief compliance officer file is a NYSE-listed payments company in New York: shortlist in week 3, accepted offer in week 10, September 2026. Retained terms on that seat: a fee of 25-30% of total first-year compensation, a retainer of 30% of the fee, and a 12-month replacement. Parent desk: compliance and regulatory recruitment. Buyer guide: how to hire a chief compliance officer.

Seat: Chief Compliance Officer with an audit-committee reporting line, assessed against the September 2024 DOJ ECCP.
Map: 1,480,000+ lawyers on the research programme. 1,136 law-firm compliance and regulatory specialists in the Washington DC metro, May–June 2026.
Published file: NYSE-listed payments, New York: shortlist in week 3, accepted offer in week 10, September 2026.
Terms: Retained only. 25-30% of total first-year compensation. Retainer of 30% of the fee. 12-month replacement.
Degree: A JD is not required. Examinations sat are the evidence on the published file.
Market context: Georgetown Law, accessed June 2026: Washington, DC is the second-largest legal market in the country, with ~80,000 lawyers in the region.

02 DOJ ECCP, September 2024

Three questions prosecutors will ask. The shortlist has to survive all three.

I
Is the programme well designed for this company's line of business? A payments chief compliance officer is not a life-sciences chief compliance officer. We map people who have sat the examination this company will sit, in this product, not authors of a generic code of conduct.
II
Is it adequately resourced and empowered to function? Headcount, budget, access to data, and the right to escalate past the business. A title over an empty programme fails this question. We write the resource test into the Mandate Blueprint in week 1.
III
Does it work in practice? On the published New York payments file, dossiers named examinations, findings, and remediation owned. The shortlist arrived in week 3. The accepted offer arrived in week 10.

03 Reporting line

Audit committee. Working line to the GC or the CEO. Not a seat under a business P&L.

Independence is a reporting-line problem. We lock it in the Mandate Blueprint, the same week as the fee.

Solid line to audit

The chief compliance officer can reach the chair of the audit committee without going through the business. On the published NYSE payments file in New York, that was the line written in week 1.

Working line to GC or CEO

Day to day, the officer still has to live with legal, risk and the CEO. We name which, and we name the conflict if the GC is also the chief compliance officer.

What we will flag

Reporting into a business unit, a bonus set by the business the programme oversees, or a GC who will not share the board calendar. Any of those is a design defect under the September 2024 independence test.

What this is not

A privacy officer with a compliance title, or an MLRO asked to own the whole programme. Those seats are different products. Privacy: chief privacy officer search. Financial crime: sanctions and AML recruitment.

04 JD versus non-JD

The degree is a credential. The examination is the evidence.

We brief both lawyers and non-lawyers into chief compliance officer seats. A JD helps when the officer will also own investigations, an employment overlay, or the privilege line with the GC. It does not help when the company needs someone who has already sat a BSA exam, an FDA inspection, or a prudential review and can walk the audit committee through what failed. The scorecard says which, before outreach starts.

If the company actually needs a GC who happens to own compliance, that is a general counsel succession or a first general counsel with a compliance-heavy brief. A bank, broker-dealer, or payments GC, including the question of whether that officer is also the chief compliance officer, is a bank general counsel search. If the company actually needs a GC who happens to own compliance, that is a general counsel succession or a first general counsel with a compliance-heavy brief — not a CCO search with a law degree bolted on. A bank, broker-dealer, or payments GC, including the question of whether that officer is also the CCO, is a bank general counsel search. An asset manager, hedge fund, or family office GC, including a combined chief compliance officer seat, is an asset management general counsel search.

05 Sector perimeters

Four perimeters we brief as chief compliance officer searches, not as generic risk roles.

Financial services

Banks, asset managers, private credit. Prudential, conduct, and financial crime, often beside an MLRO. The May–June 2026 snapshot counts 1,136 law-firm compliance and regulatory specialists in the Washington DC metro.

Pay

Payments

Licensed principals and the supervisors who examine them. The published file is a NYSE-listed payments company in New York: audit-committee line, shortlist in week 3, accepted offer in week 10, September 2026.

Life sciences

FDA, EMA, quality systems, promotion. A chief compliance officer here is the programme owner, distinct from a GCP auditor and from the general counsel.

Energy

Sanctions, projects, environmental, and listed disclosure. Sanctions specialists sit on the sibling desk.

Sibling seat: sanctions and AML recruitment. Markets: compliance recruitment in New York City, Houston, Boston, Dallas. Company hub: legal hiring for companies.

06 Published file and terms

Week 3 to shortlist. Week 10 to an accepted offer. On the file we publish.

1,480,000+: Lawyers on the research programme map.; Sartori research programme
1,136: Law-firm compliance and regulatory specialists, Washington DC metro.Largest single cluster in that map.; Case studies, May–June 2026
Week 3: Shortlist on the published NYSE payments file, New York.; Case study, September 2026
Week 10: Accepted offer on that same file.; Case study, September 2026

Week 1 Mandate Blueprint
September 2024 ECCP tests, audit line, JD or not, perimeter. 12-month replacement already in the letter.
Weeks 1–2 Map examinations
Sitting officers who have sat this supervisor. The map is 1,480,000+ lawyers.
Week 3 Shortlist
On the published New York payments file, the shortlist arrived in week 3. Dossiers name examinations.
Week 10 Accepted offer
On that file, the accepted offer arrived in week 10, September 2026. Not published as a median.
After start 90-day checks
12-month replacement. Off-limits for 24 months on the client's legal and compliance department.

07 New York

Chief compliance officer, NYSE-listed payments. Audit-committee line. Week 3. Week 10.

Payments · NYSE-listed · New York

Chief Compliance OfficerRead the case study

Situation: The audit committee wanted an officer who could survive the September 2024 ECCP independence and resourcing tests, not a policy author.
Approach: Retained. Audit-committee reporting line locked in week 1. Mapped sitting payments chief compliance officers who had sat examinations. Blind outreach.
Outcome: Shortlist in week 3. Accepted offer in week 10. September 2026. Fee 25-30% of total first-year compensation, retainer 30% of the fee, 12-month replacement.

Timeline: Shortlist in week 3; accepted offer in week 10.

Compliance recruitment

Parent desk for chief compliance officer, MLRO, regulatory counsel, and privacy leadership.

Compliance parent

Hiring a CCO

The buyer guide that sits beside this search: ECCP, reporting line, JD versus non-JD.

Read the guide

Chief Privacy Officer

When the seat is privacy and GDPR Articles 37-39, not the ECCP.

Chief privacy officer search

Chief Compliance Officer search — questions

What does the DOJ ECCP require of a Chief Compliance Officer?

The September 2024 Evaluation of Corporate Compliance Programs asks whether the programme is well designed for this company's line of business, adequately resourced and empowered, and working in practice. A chief compliance officer who cannot reach the audit committee fails the independence test before the first interview. Source: DOJ Evaluation of Corporate Compliance Programs, September 2024.

Must a CCO be a lawyer?

No. A JD is a credential, not the evidence. The published New York payments file scored examinations sat, not the degree. A payments chief compliance officer who has lived a supervisor's examination will outrank a policy author who has not.

Who should the CCO report to?

On the published file the reporting line ran to the audit committee, with a working line to the GC. That is the line we lock in week 1 for listed and dual-regulated companies. Dual-hatting the GC as chief compliance officer is a design choice we will name, not a default.

How long does a chief compliance officer search take?

The published file, a NYSE-listed payments company in New York, reached a shortlist in week 3 and an accepted offer in week 10 (September 2026). We do not publish a median across a placement book. Read the New York payments chief compliance officer file.

What chief compliance officer work do you publish?

One chief compliance officer file is published: NYSE-listed payments, New York, shortlist in week 3, accepted offer in week 10, September 2026. The May–June 2026 market snapshot counts 1,136 law-firm compliance and regulatory specialists in the Washington DC metro. The research programme maps 1,480,000+ lawyers. Parent desk: compliance and regulatory recruitment.

What is the replacement guarantee on a CCO search?

Retained chief compliance officer searches carry a 12-month replacement, the same window as GC and CLO searches. The fee is 25-30% of total first-year compensation, with a retainer of 30% of the fee paid at engagement. Off-limits run 24 months on the client's legal and compliance department.

Which sectors do you run CCO searches in?

Financial services, payments, life sciences and energy are the perimeters described on the published file and the sector pages beside it, plus listed groups in other regulated trades. ACC's 2025 Chief Legal Officer Survey names risk, compliance, data privacy and regulatory change as the issues CLOs rank first. See hiring a chief compliance officer and chief privacy officer search when the seat is privacy, not the ECCP.

Sources

Figures on this page, and where they are published.

Sources

7 references

Independence, resourced

Brief the chief compliance officer against the tests a prosecutor will ask.

September 2024 ECCP. The published New York payments file closed in week 10. Fee, 12-month replacement, and 24-month off-limits go in the letter before we call anyone.

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