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Compliance officer job description: which rules, nine duties, and the appointments to name

A compliance officer job description that starts with scope: which rules the role owns, nine duties, what independence requires, the FCA compliance oversight function and the ICO's data protection officer, what to measure, and a template.

Published Updated 11 min read

TL;DR

  • Compliance officer describes at least four jobs: regulatory compliance in a regulated firm, corporate compliance and ethics, operational or sector compliance such as health and safety or food standards, and inspection or licensing work. O*NET's Compliance Managers occupation covers those who “plan, direct, or coordinate activities of an organization to ensure compliance with ethical or regulatory standards”, which is broad because the work is.
  • Two appointments have to be named explicitly in a UK job description if they apply. In an FCA-regulated firm, a senior management function carries a statement of responsibilities and a personal Duty of Responsibility: the FCA states that if a firm breaches a requirement, “the SMF responsible for that area could be held accountable if they did not take reasonable steps to prevent or stop the breach”. And a data protection officer, where one is required, “must be independent, an expert in data protection, adequately resourced, and report to the highest management level”.
  • Independence is the part that fails quietly. A compliance officer who reports to the person whose decisions they check, who has no budget, and who first hears about a change after it has shipped, has the title and none of the job.

"Compliance officer" tells you what somebody worries about, not what they do. The job in a bank, a food manufacturer, a charity and a software company have almost nothing in common except the sentence at the top of the advert.

This article sets out a compliance officer job description that starts where it should: which rules the role is responsible for. Then nine duties, what independence actually requires, the two UK appointments that have to be named, what to measure, and a template. It is general information about the role, not legal or regulatory advice.

Compliance runs on defined steps, evidence and sign-offs, which is exactly the kind of work that should not live in an inbox. See how New Dynamics workflows let you define your own stages, forms and approvals, with a completion view instead of a spreadsheet.

Compliance handles the obligations; risk handles the uncertainty nobody regulates. Our risk manager job description covers the neighbouring role and where the two registers should meet.

Four jobs, one title

The four kinds of compliance officer role: regulatory compliance in a regulated firm, corporate compliance and ethics, operational or sector compliance, and inspection and licensing.
Answer this before writing anything else in the advert.
  • Regulatory compliance in a regulated firm: financial services, insurance, gambling, energy, healthcare. The rules come from a named regulator and carry personal accountability.
  • Corporate compliance and ethics: anti-bribery, sanctions, competition, modern slavery, conflicts of interest, the code of conduct and the speak-up line.
  • Operational or sector compliance: health and safety, food safety, environmental permits, product standards, professional registration.
  • Inspection and licensing: checking that other organisations comply. O*NET's Compliance Officers occupation sits here, with tasks such as visiting establishments "to verify that valid licenses or permits are displayed and that licensing standards are being upheld" and reporting "law or regulation violations to appropriate boards or agencies".

For the in-house versions, the closest occupational description is O*NET's Compliance Managers: those who "plan, direct, or coordinate activities of an organization to ensure compliance with ethical or regulatory standards".

Before writing anything else, answer one question: which rules is this person responsible for? List them. A compliance advert without that list is asking candidates to guess at the job.

Nine duties

Compliance officer duties in nine groups: know the rules, write the policies, train, monitor, investigate, report externally, report internally, advise early, and take confidential reports.
A speak-up line nobody is trained to handle is worse than none.
  1. Know the rules that apply, and keep up: "keep informed regarding pending industry changes, trends, or best practices".
  2. Write and maintain the policies. "Verify that all regulatory policies and procedures have been documented, implemented, and communicated", and "disseminate written policies and procedures related to compliance activities".
  3. Train people. "Provide employee training on compliance related topics, policies, or procedures", and "discuss emerging compliance issues to ensure that management and employees are informed about compliance reporting systems, policies, and practices".
  4. Monitor. "Conduct periodic internal reviews or audits to ensure that compliance procedures are followed", and "monitor compliance systems to ensure their effectiveness".
  5. Investigate. "Identify compliance issues that require follow-up or investigation" and "conduct or direct the internal investigation of compliance issues".
  6. Report externally. "File appropriate compliance reports with regulatory agencies", and where required "report violations of compliance or regulatory standards to duly authorized enforcement agencies".
  7. Report internally. "Prepare management reports regarding compliance operations and progress", and make sure the board sees the real picture rather than a green dashboard.
  8. Advise. Be in the room before decisions are made, and "consult with corporate attorneys as necessary to address difficult legal compliance issues".
  9. Take confidential reports. "Serve as a confidential point of contact for employees to communicate with management, seek clarification on issues or dilemmas, or report irregularities", and "maintain documentation of compliance activities, such as complaints received or investigation outcomes".

Duty nine is the one most often written into a job description and least often resourced. A speak-up line with nobody trained to handle what comes through it is worse than no line at all.

Independence, and what makes it real

Three conditions for compliance independence: a reporting line that is not the person being checked, resources of its own, and early involvement before decisions are made.
Hearing about the new product from the advert is not control.

Three conditions, and the role is decorative without them:

  • A reporting line that is not the person being checked. Directly to the board, an audit committee or the chief executive, with a route to escalate that does not require permission.
  • Resources of its own. Budget, time, and access to systems and records without asking the business to hand them over.
  • Early involvement. Seeing a change before it launches rather than after. A compliance officer who first hears about the new product from the advert is being used as insurance rather than control.

The ICO makes the same point about the data protection officer role, requiring that a DPO "must be independent, an expert in data protection, adequately resourced, and report to the highest management level".

The appointments to name

Two UK arrangements are specific enough that a job description has to be explicit.

An FCA senior management function

In firms regulated by the Financial Conduct Authority, compliance oversight is normally a senior management function, and that brings personal accountability.

The FCA's page on the Senior Managers Regime states that "every SMF must have a 'Statement of Responsibilities' (SoR) that clearly states what they are responsible and accountable for", and that the FCA makes particular functions SMFs "so that we know who a firm's most senior decision makers are and to make sure firms clearly allocate responsibilities to those key individuals".

The consequence is stated plainly: "every SMF holder will have a Duty of Responsibility under the Financial Services and Markets Act 2000 (FSMA). This means that if a firm breaches one of our requirements, the SMF responsible for that area could be held accountable if they did not take reasonable steps to prevent or stop the breach." It adds that "SMFs must be fit and proper to do their jobs and firms need to assess their ongoing fitness and propriety at least annually".

Solo-regulated firms fall into Enhanced, Core or Limited Scope categories, which determine which functions and prescribed responsibilities apply, and "firms are responsible for determining which category they fall into". Which functions apply to your firm and role is a matter for the firm's own analysis and the FCA Handbook.

If a role carries an SMF, the advert should say so, because the person is accepting personal accountability along with the salary.

A data protection officer

The ICO explains that the UK GDPR "introduces a duty for you to appoint a data protection officer (DPO) if you are a public authority or body, or if you carry out certain types of processing activities". DPOs "assist you to monitor internal compliance, inform and advise on your data protection obligations, provide advice regarding Data Protection Impact Assessments (DPIAs) and act as a contact point for data subjects and the Information Commissioner's Office".

Three details matter for a job description. The DPO "can be an existing employee or externally appointed". Several organisations can share one. And where an organisation appoints a DPO voluntarily, the ICO is clear that "the same duties and responsibilities apply", so "DPO" cannot be added to a compliance officer's title as a courtesy.

  • Internal audit provides independent assurance that controls work, including compliance's own. Our audit manager post covers it. Compliance designs and runs controls; audit checks them.
  • Legal advises on what the law requires and defends the organisation. Compliance builds the day-to-day system that keeps the organisation inside it.
  • Quality assurance applies the same discipline to the product or service rather than to regulation; see our quality assurance job description.

Small organisations combine these, which is fine as long as the combination is deliberate and the conflict is named.

What to measure

Not "number of breaches", which rewards not finding things. Better:

  • Policy currency: the proportion reviewed on schedule.
  • Training completion, and the retest rate for those who failed it.
  • Monitoring coverage: what proportion of the risk universe was reviewed this year.
  • Time to close findings and actions, by severity.
  • Speak-up volume and outcomes, with an eye on silence as a warning rather than a success.
  • Early involvement: the share of new products, systems or processes where compliance was consulted before launch.

A compliance officer job description template

Job title: Compliance officer / manager

Reports to: [board / audit committee / chief executive]

Scope, the rules this role owns: [list the regimes, regulations and standards]

Regulatory appointments: [does this role hold an FCA senior management function? Is it the data protection officer? If neither, say so.]

Purpose: Keep the organisation inside the rules that apply to it, by making the right thing the easy thing and by catching the wrong thing early.

Responsibilities

  • Maintain a current understanding of the applicable rules and of forthcoming changes.
  • Own the compliance policy framework and ensure policies are documented, implemented and communicated.
  • Deliver compliance training and awareness across the organisation.
  • Run a risk-based monitoring programme and report the results.
  • Investigate compliance issues and document outcomes.
  • Make required regulatory filings and notifications.
  • Report to management and the board on compliance status, issues and progress.
  • Advise on new products, processes and systems before launch.
  • Operate the confidential reporting route and handle what arrives through it.

Independence: reporting line, budget, system access and escalation route.

You will need: [sector knowledge and qualifications]; the ability to write plainly; the willingness to be unpopular occasionally.

What the advert should say

  1. The rules. Which regimes and standards the role owns.
  2. The appointments. SMF, DPO, MLRO or none.
  3. The independence. Reporting line, budget, and access.
  4. The size of the job. Sites, headcount, jurisdictions, and whether anyone reports in.

Frequently asked questions

What does a compliance officer do?

Keeps an organisation inside the rules that apply to it: knowing the rules, writing and maintaining policies, training people, monitoring whether procedures are followed, investigating issues, making regulatory filings, reporting to management and the board, advising on changes before they launch, and operating a confidential route for employees to raise concerns.

What are the main duties of a compliance manager?

Identifying compliance issues that require follow-up heads the occupational task list, alongside conducting or directing internal investigations, verifying that regulatory policies and procedures have been documented, implemented and communicated, conducting periodic internal reviews or audits, monitoring compliance systems for effectiveness, filing reports with regulatory agencies, providing employee training, serving as a confidential point of contact for employees, and preparing management reports.

What is the difference between compliance and internal audit?

Compliance designs and runs the controls that keep an organisation inside the rules. Internal audit independently checks that controls work, including compliance's own. Combining them in a small organisation is common, but the conflict should be named and managed rather than ignored.

Does a compliance officer need to be approved by a regulator?

In some sectors, yes. In FCA-regulated firms, compliance oversight is normally a senior management function, which requires a statement of responsibilities and brings a personal Duty of Responsibility: the FCA states that where a firm breaches a requirement, the senior manager responsible could be held accountable if they did not take reasonable steps to prevent or stop it. Which functions apply depends on the firm's category and the Handbook. This is general information, not legal advice.

Is a compliance officer the same as a data protection officer?

No. A DPO is a specific role required in some circumstances, which the ICO says must be independent, an expert in data protection, adequately resourced and reporting to the highest management level. The same duties apply even where an organisation appoints one voluntarily, so the title should not be added to a compliance role casually. One person may hold both, if the resourcing and independence are real.

How should a compliance officer be measured?

Not on the number of breaches found, which discourages finding them. Use policy currency, training completion, monitoring coverage of the risk universe, time to close findings by severity, speak-up volume and outcomes, and the share of new products or processes where compliance was consulted before launch.

Your next step: list the rules before you write the advert

  1. Write down every regime, regulation and standard the role will own.
  2. State whether the role carries a senior management function, a DPO appointment, or neither.
  3. Set the reporting line, budget and system access that make independence real.
  4. Choose measures that reward finding problems rather than reporting none.

For the policy and speak-up framework the role runs on, read and download our code of conduct guide. The guide is free to read, and the PDF uses our short download form.

Want policies, training, monitoring and actions in one place, with completion visible instead of chased? Book a New Dynamics demo and bring your current compliance calendar. You can also email contact@new-dynamics.com.

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