CCOs: You’re not a “yes” person—and you’re also not the “Department of No”
Working in compliance isn’t for the faint of heart. It’s a role that requires a blend of empathy, grit, and a healthy dose of curiosity. Compliance officers are the tightrope walkers of the business world, carefully navigating the space between “yes” and “no,” between trusted advisor and enforcer. We’re tasked with ensuring that businesses act ethically and responsibly, enabling them to achieve their objectives and generate profit while maintaining the highest standards of integrity. We’re also responsible for building relationships that inspire trust and foster collaboration across the organization. It’s no wonder so many of us occasionally feel the weight of the role pressing down.
What exactly makes a great compliance officer excel in this role? In my experience, the most effective CCOs I’ve had the pleasure of working with share these key characteristics. Here are the top five traits that, in my opinion, set them apart.
Empathy
Empathy might not be the first quality you think of when it comes to compliance, but it’s one of the most important. Effective compliance officers must understand the pressures and realities employees face at all levels of the business. This isn’t about excusing unethical behavior—it’s about creating policies and programs that acknowledge the human side of decision-making.
When you approach others with empathy, you create a space where people feel safe to ask questions, raise concerns, and even admit mistakes. And that space is critical for building the kind of culture where compliance is a shared responsibility.
Inquisitiveness
Curiosity is a compliance officer’s most powerful tool. Great compliance officers ask questions—lots of them. They don’t accept “because that’s the way we’ve always done it” as an answer. They dig into processes, examine the nitty-gritty details, and strive to understand how the business really works.
This inquisitive nature allows us to identify risks that might otherwise go unnoticed and ensure that the rules we implement make sense in the real world. It’s not enough to sit behind a desk and push out policies. To make a meaningful impact, you have to get out there, listen to employees, and understand how things operate on the ground.
Directness
One of the most challenging aspects of being a compliance officer is having the courage to speak up, especially when it’s uncomfortable. A few years ago, I attended a session led by Justin Paperny, who recounted his journey from a successful stockbroker at Bear Stearns and UBS to serving time in Taft Federal Prison Camp. He shared a pivotal reflection about his compliance manager—a “yes” person he was able to manipulate with ease. Paperny put it bluntly: “If you are a people pleaser, get out of compliance. You’ll be exploited just as I exploited my compliance manager.”
Those words have stayed with me ever since. As compliance officers, we must be willing to hold the line, even when it means challenging senior leadership or delivering difficult truths. Directness doesn’t mean being confrontational—it means being clear, confident, and unwavering in our principles. Avoiding tough conversations might feel easier in the moment, but it risks letting small problems grow into major crises. In this role, candor and courage are non-negotiable.
Resilience
Let’s be real: compliance is tough work. You may feel like the perpetual bearer of bad news or the person constantly reminding others what can’t be done. It’s exhausting. And it can be lonely.
But resilience is what keeps us going. It’s what allows us to bounce back after a difficult conversation, dig into the next challenge, and keep advocating for what’s right. Resilience isn’t about being unshakable—it’s about showing up, even when the work feels overwhelming.
Courage
Courage ties all these characteristics together. Being empathetic, inquisitive, and direct takes bravery—especially in an environment where you may feel outnumbered or underappreciated. Sometimes, this courage may even mean facing potential retaliation or exclusion for speaking truth to power. In some cases, it might even mean recognizing when a situation is beyond repair and having the courage to walk away from a role or organization that is no longer aligned with your own ethical compass. But courage is what allows us to stay true to our values, make difficult decisions, and push for change in the face of resistance.
Courage doesn’t mean you won’t feel fear or doubt. It means acting in spite of them. And as compliance officers, our courage is often what inspires others to step up and do the same.
Recognizing the challenges and celebrating the work
If you’re reading this and nodding along, you know this isn’t easy work. Being a compliance officer means balancing competing priorities, managing complex risks, and making decisions that aren’t always popular. But it also means being part of something bigger—helping to build a culture of integrity that benefits everyone.
So, to all my peers in compliance: You’re seen. You’re doing work that matters. And while the road may not always be smooth, the impact you’re making is profound.
Keep asking questions. Keep having the hard conversations. Keep showing up. Because that’s what great compliance officers do.
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