Executive search and advisory firm BarkerGilmore LLC just released its 2024 Compliance Compensation Report, reflecting changes in Chief Compliance Officer (CCO) total compensation by factoring in salary, bonus, and long-term incentives; the type of organization (public, private, nonprofit); and the organization’s revenue.

The research data was collected from a broad random sampling of senior level compliance professionals throughout the US through an online survey.

Two key findings: There were year-over-year increases in CCO median base plus bonus compensation for public companies and nonprofits, and a slight decrease for private companies. And salaries increased for CCOs across the reported seven industry categories, but the rate of those increases declined year-over-year – except for the financial services sector, where increases remained the same.

General compensation trends

The increases in year-over-year median salary plus bonus looked like this, depending on organization type:

• Public: up 7%, to $419,000 from $391,262.
• Private: down 1% to $299,541 from $302,000.
• Nonprofit: up 12% to $250,000 from $223,810.

Industry sector salary increases and decreases in relation to 2023 were as follows:

• Financial services: rate of increase stayed at 5%.
• Technology: rate of increase declined to 4% from 6%.
• Healthcare/Life Sciences: rate of increase declined to 2% from 5%.
• Energy: rate of increase declined to 1% from 5%.
• Consumer: rate of increase declined to 2% from 6%.
• Industrial & Manufacturing: rate of increase declined to 2% from 7%.
• Professional Services: rate of increase declined to 0% from 4%.

The compensation breakdown at public firms based on size was as follows, and includes salary plus bonus plus long-term incentives (LTI – such as stock):

• Firms <$500m: Total compensation ranged from $223,000 to $725,000.
• Firms $500m to $1 billion: Total compensation ranged from $250,000 to $903,000.
• Firms $1 billion to $5 billion: Total compensation ranged from $291,000 to $971,000.
• Firms $5 billion+: Total compensation ranged from $329,000 to $1,311,000.

The CCOs at firms in the smallest-sized category (<$500m) saw increases in salary this year of 3%; and those working at the largest organizations ($5b+) saw increases in salary of 4%. Oddly, all of those businesses in the middle categories by size saw no salary increases, although those amounts don’t include bonuses or LTI, of course.

Speaking of bonuses, working at the largest entities pays off well there too, as the average bonus reported was 35% of salary, as opposed to the firms in the smallest category, in which the average bonus was 20% of salary.

“As the compliance discipline continues to grow in importance as a risk management discipline, we expect CCO compensation increases to continue in the year ahead.”

John Gilmore, Managing Partner at BarkerGilmore

And there is a pay differential in having a JD degree – but that’s far more pronounced if you work at a public company. At a public company, that law-degree pay differential is $295,000; at a private firm it is $61,000, and at a nonprofit, it is $92,000.

In most firms (53%), the CCO reports to the General Counsel with the CEO coming in second at 30%. Interestingly, CCOs at nonprofits are much more likely to report to the CEO (58%) than at both public companies (30%) and private companies (43%).

Gender differences

Total CCO compensation for both public and private companies was higher for men than women; however, the trend reversed at nonprofits, where women were paid more than their male counterparts. The breakdown was as follows:

• Public company differential was +29% for men.
• Private company differential was +9% for men.
• Nonprofit firm differential was +9% for women.

At public companies, men reported a base average salary of $257,500, an average bonus of $77,250 and a total compensation of $362,500. Women reported a base salary of $233,000, and average bonus of $43,500, and an average total compensation of $297,000.

At private companies, men reported an average salary of $244,500, an average bonus of $60,900, and total compensation of $324,000. Women reported an average base of $222,500, average bonus of $39,300, and average total compensation of $282,317.

Interpreting the data

According to BarkerGilmore’s Managing Partner, John Gilmore: “We attribute the slowing of salary increases to various factors, including tighter post-COVID corporate hiring budgets, and economic and political uncertainty. While our executive search business experienced a softening of demand for compliance professionals in 2023, we have witnessed a robust turn around in 2024 as positions opened due to internal promotions, resignations, and retirements.”

“The good news is that positions at the top cannot go unfilled for long. As the compliance discipline continues to grow in importance as a risk management discipline, we expect CCO compensation increases to continue in the year ahead.”

BarkerGilmore has reported legal and compliance industry compensation trends since 2015, and GRIP reported last year’s results as well.

The demographic details and data analysis used by the firm in assembling the report are described there, but a couple of things stood out. First, 56% of the respondents were from private firms; 29% from public ones, and only 15% from nonprofits. And by race, the CCO respondents were almost all White (81%), with African-American next (6%), then Asian (5%), and Hispanic or Latino/Latina (3%).