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How do compliance officers vote with their feet?

When a compliance officer needs to vote with his feet, the key ingredients to look for at the next job are, among other things, a chief compliance officer who reports to an independent board, and incentives or bonus pay for outstanding work. 

A compliance officer might also vote with his feet by leaving the field, either because no company with those criteria is available, or because he dislikes the profession itself. There is no shame in it. When it comes to a stay or go decision, a CO’s personal happiness and family come first, and there is much good to be done in the world in other ways.
From what I’ve learned from readers’ comments, compliance officers also fear they will be forced to resign to avoid violence, retaliation or being cornered to do illegal or immoral acts, especially the under-appreciated COs in China, India and other countries outside America. This is a crisis for a CO and for the profession as well. No slogan or pep talk can solve a problem that needs collective discussion and action.

For what it’s worth, my advice is always to try, if possible, to manage the crisis — and resign, if it comes to that, in a calm, deliberate way. Make the most of the support available from friends and family. Rely on professional counseling and legal advice.

And remember: It’s not you. Sometimes it really comes down to the job itself, and another consequence of corruption.


Michael Scher is a contributing editor of the FCPA Blog. He has over three decades of experience as a senior compliance officer and attorney for international transactions. He is affiliated with ethiXbase, the owner of the FCPA Blog. He can be contacted here.

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