At Large: Are compliance officers generalists or specialists?

All compliance officers have special skills that set them apart from everyone else. They’re “subject matter experts” in ethics and compliance. That makes them unique. But within the ranks of compliance officers, who are the generalists and specialists? And where do we find them?

I examined about a year of postings on the FCPA Blog’s Job Board, some of which are also posted on other sites. Some patterns emerged and I’m sharing what I found. But with a big caveat: This isn’t a scientific survey with peer-reviewed results. My sample wasn’t huge or entirely random. Employers who post on the FCPA Blog Job Board and elsewhere are often looking for a higher experience level and that skews the results.

With that warning in mind, here’s the question: How did companies describe the compliance candidates they were looking for?

Here’s what I found.

Employers seeking mid-level compliance officers typically required two levels of expertise. First, generalist expertise about anti-corruption laws and conflicts of interests, and the ability to administer ethics and compliance programs. Second, specialist expertise, usually specific to the industry.

For example, a healthcare company wanted a mid-level compliance officer with general knowledge of the FCPA and UK Bribery Act. The requirement also included “Anti-Kickback, False Claims Act, sunshine and transparency laws, PhRMA Code, EFPIA Code, ABPI Code and similar laws, regulations and industry standards in the United States and Europe.”

A government contractor advertised for a mid-level compliance officer who could handle ethics and compliance issues, with special knowledge of the “Federal Acquisition Regulations (FAR), Defense Federal Acquisition Regulations (DFARS), public law (to include applicable international law), government regulations, prime contract flow through, customer contractual requirements, and business system processes.”

A financial institution sought a mid-level compliance officer with knowledge of the FCPA and UK Bribery Act, and also AML/KYC regulations and industry guidelines (FSA, JMLSG, 3rd EU Money Laundering Directive, MiFID, US PATRIOT Act, U.S. Bank Secrecy Act, and “possible implications of financial sanctions on banks and financial institutions (OFAC, HM Treasury, EU and UN sanctions).” Candidates also needed to display a “very good understanding of the end-to-end KYC and client on-boarding processes.”

Other industries with similar specialist requirements include energy services, agriculture, shipping, education, transportation, broker-dealers, and so on.

Top-level compliance jobs are for experienced generalists. Chief compliance officers and often their deputies manage the compliance specialists. They’re described in job postings as “big-picture” generalists, able to design, implement, and oversee global ethics and compliance programs.

One big tech company said the successful CCO candidate would be “a strategic leader and function-builder who can operationalize and manage a world-class global compliance function.”

Another said its senior compliance and ethics manager would be “overseeing and supporting the day-to-day operations of . . . various global ethics and compliance programs and initiatives, including Code of Conduct, global compliance training, Conflicts of Interest disclosure process, and employee communication and engagement and FCPA.”

A life science firm looking to fill a “Global Compliance Lead” position sought a generalist, but with industry experience — “adherence to international anti-bribery/anti-corruption laws, privacy and data security laws and other compliance frameworks applicable to medical device manufacturers and diagnostic laboratories.”

What about entry-level compliance jobs? Most that I’ve seen are in the financial services sector. They involve a lot of KYC work and onboarding of new clients and account holders. The positions are often focused on industry-specific laws and regulations. Entry-level compliance officers with an eye on mid-level positions will also want to acquire knowledge about anti-corruption statutes, conflict of interest rules, and the like.

Lawyers and other professionals? Roughly 20 percent of the job postings I examined either required the candidate to hold a JD or said a JD was “preferred.” Some high-level compliance positions reported to the general counsel and were part of the law department, but with a compliance title or a joint law department / compliance title.

Analysts? At a Big Four firm, a compliance-related job was “Lead Analyst, U.S. Anti-Corruption & Trade.” The candidate would help “establish policies, processes, and controls to support . . . compliance with applicable anti-corruption regulations, including the Foreign Corrupt Practices Act (FCPA) and trade and economic sanctions.” Is that a compliance generalist with trade sanctions expertise, or a trade sanctions specialist who also knows the FCPA?

Investigators? A telecommunications firm posted for a “Senior Corporate Investigator” to  join a team investigating “alleged fraud, corruption, and regulatory breaches.” The candidate needed to be familiar with organizational behavior and have knowledge of financial forensics, data analytics, the FCPA, UK Bribery Act, and other anti-corruption laws. DOJ or SEC experience was a plus. The specialized investigative skills set that job apart from a compliance officer.

Final note. I’ve used the generalist and specialist categories as a way to describe various skill sets employers often look for in their compliance function. The categories are more fluid than I’ve shown, and by no means does one category rank “above” or “below” another. By referring to generalists and specialists, my intention isn’t to suggest that compliance officers or related professionals in one category are more or less valuable than those in another category. My only purpose is to show how prospective employers describe their compliance jobs and the candidates they hope to attract.