Is the compliance profession stressful? We suspect the answer to the question can be summarized as “yes.” But we don’t know for sure, nor to what extent. We don’t know the rates of mental health issues experienced by compliance officers. We ultimately know very little about the variation and stratification of working conditions in the compliance field.
Compliance may well be more stressful than many other occupations. It may be more stressful than the average job. Compliance officers may experience mental health issues at higher rates, report higher instances of depression, anxiety or burnout and enjoy less professional fulfillment than others. But we simply don’t know for sure.
http://t.co/PxaSIv3Qdp I am convinced that Chief Compliance Officer is the most stressful job a person can have at a company. Zero…
— Steve Meister (@painkillerlaw) April 9, 2013
On the other hand, some individuals and organizations view compliance to be a relatively stress-free job. Every year CareerCast scores the stress levels of different jobs by analyzing Bureau of Labor Statistics data for 11 different categories (e.g., travel, risk of death, deadlines). The report regularly finds compliance to be among the least stressful jobs. Redditors on one thread comparing compliance to practicing law agreed that the former offered a better work-life balance.
— Richard Chambers (@rfchambers) January 31, 2017
We really don’t know just how stressful the compliance sector is as a whole. That is why we’re launching a survey on self-reported working conditions in the compliance field. With it, we hope to reach professionals across sectors and ask them questions like: How does your job affect your mental health? Do you have adversarial relationships at work because of your function? Do you believe you are compensated adequately?
We want to hear from you. Access the survey here. Read on to learn more about what we do know about stress and mental health in the compliance field and why we are launching this survey.
Why Are We Doing This?
CCI provides a platform and a mirror for the compliance sector. That is a bias in and of itself. But as an independent digital publication, we also seek to maintain distance between ourselves and any individual or group with vested interests. We are conducting this survey on our own accord and without sponsorship of any sort, because we seek to provide insight to our readers while establishing a benchmark that will serve as a reference for the future. No third parties are involved in any promotional or marketing relationships.
It should also be noted that we acknowledge we are not experts in mental health, survey design or research analysis. That’s why we partnered on this project with a professional, independent research expert. Tamara Altman, who holds a Ph.D. in clinical psychology from UCLA, has over 20 years of experience in academic, nonprofit, government and corporate research projects.
What Is a Compliance Officer?
Many surveys of the field focus on chief compliance officers. But in reality, the vast majority of compliance workers are not found in the C-suite.
We borrow the definition recognized by the U.S. Bureau of Labor Statistics. According to BLS classification, a compliance officer is a professional who must “[e]xamine, evaluate and investigate eligibility for or conformity with laws and regulations governing contract compliance of licenses and permits, and perform other compliance and enforcement inspection and analysis activities not classified elsewhere.” Check here for more information about the BLS classification.
In some working conditions, compliance officers cooperate with other departments to ensure their employer meets its goals while mitigating risk and remaining within the confines of the law. In other settings, they are treated as a check-the-box release valve that can shunt off pressure when operations get too hot and attract too much regulatory attention.
Writing under a pseudonym, one Singapore bank manager who took a compliance role recalls his personal experience with the latter situation: “[A] lot of the issues that compliance people face are caused by the front-office or at least involve the front-office in a major way … [T]here was an attitude among bankers that compliance was an annoyance that could be passed down to my team and forgotten about. That in itself was the major problem.”
In other conditions – potentially quite a few – the role of compliance is unclear and fluid. As Asia Quality Focus Compliance Officer Vicky Yu recalls when she assumed her role, “When the marketing team was talking about the marketing plan under GDPR, I marked in my notebook that our marketing plan needed to meet all the local regulations. When my boss raised concerns to me about compliance issues in collecting payments in a southeast Asian country, my first reaction was that he was addressing the wrong person – it should be the accounting team. I have done a lot of learning on how some topics that seemed to be completely unrelated are connected in compliance.”
We suspect that the more chaos, uncertainty and pressure is thrown into the compliance function, the more stressful the job will be. While we often hear instances like those cited above, we don’t know how widespread they are.
Stress Associated with Compliance – What We Think We Know
To our knowledge, just one effort has been made to quantify stress levels in the field. In 2011, the Society of Corporate Compliance and Ethics (SCCE) and Health Care Compliance Association (HCCA) polled its members about their stress and well-being in the workplace (PDF download). They received a significant sample of responses (“over 970”), and drew interesting conclusions. For example, 60 percent of respondents reported they had considered leaving their jobs. Fifty-eight percent said they felt isolated or worked in an adversarial relationship.
This survey was notable for another reason: It has been cited by virtually every writer, journalist and blogger who has taken up the subject of stress in the compliance field. That response speaks to the value of such an endeavor and the impact of its findings.
Ten years later, we believe it is time for an update. Just like any profession, a lot can change in a decade. But regarding compliance in particular, the 2010s proved highly disruptive. Taking the Dodd-Frank Wall Street Reform Act alone, Baker Institute for Public Policy Fellow Thomas Hogan estimates (PDF download) that the legislation increased banks’ compliance costs by an aggregate $50 billion per year.
Besides this growth, the job has also gotten riskier. In September 2015, former Deputy Attorney General Sally Yates issued the memo titled “Individual Accountability for Corporate Wrongdoing” (PDF download) (also known as the Yates memo). The DOJ guidance called for prosecutors to target individuals who were responsible for corporate crimes. Yates extended its purview to those who knew corporate crimes were being committed, but did not speak out, including compliance officers. The Wall Street Journal described it as the “shot heard around the (corporate) world.” Suddenly, compliance officers faced real consequences if they didn’t ensure their company toed the line.
This memo was tested shortly after it was issued by the Volkswagen emissions scandal. In 2017, the FBI arrested Oliver Schmidt, who worked as the car manufacturer’s senior emissions compliance manager, for the role he played in the scheme. In subsequent crackdowns on opioid drug distributors, compliance officers have also been held responsible with criminal charges.
Other laws, like the EU’s General Data Protection Regulation, the California Consumer Privacy Act and the Corporate Transparency Act have continued to shake up the field. Global trends like digital transformation, climate change, #MeToo, Black Lives Matter, cyberattacks and, of course, COVID-19, have also left an indelible mark on the compliance profession.
As a result, the scope of the compliance profession has expanded rapidly. In 2011, a typical compliance officer might have helped the employer navigate various forms of risk, along with a wide range of applicable legislation and regulations. Since then, a number of potential focuses have been added to the compliance to-do list, including environmental, social and governance (ESG) issues; diversity, equity and inclusion (DEI); data protection, know your customer (KYC) and cybersecurity; cryptocurrency and blockchain technology; and the uses of artificial intelligence and machine learning, among many others.
Taking the above into account, a question as broad as “Is compliance stressful?” is not very useful. We want to dig deeper and ask questions like: What is the disparity in stress levels across the compliance field? Does that stress translate into mental health issues? And what conditions maximize or minimize stress in the compliance role?
This survey will allow for a number of insights going forward. But more immediately, it will let currently practicing compliance officers compare their own experience against that of their peers. Business leaders, furthermore, will be able to gain a better understanding of what leads to a successful, healthy compliance program.