FCPA Compliance Jobs and Salary
- The FCPA prohibits companies from bribing foreign officials and requires companies to maintain adequate books, records, and internal controls.
- Federal investigations and prosecutions of compliance officers has increased substantially. The SEC and DOJ have expressed their intent to further ramp up their investigative efforts to prosecute individuals and companies suspected of engaging in behavior that violates the FCPA.
- Compliance jobs are therefore a risk-intensive opportunity. Companies have compensated for these heightened risks by increasing the salary potential for various compliance jobs.
- These increases in salaries and federal government efforts to prosecute violators of the FCPA mandate that companies revitalize or re-design their compliance policies.
- Consider hiring an experienced team of FCPA lawyers to advise you on your compliance policy and how evolving internal and external trends in compliance jobs and salaries can impact your business.
FCPA Defense Team
If you need legal advice regarding compliance jobs or compensation with respect to emerging FCPA trends or are worried about FCPA allegations concerning your company, now is the time to speak to an experienced defense attorney.
Federal regulatory agencies have indicated a renewed effort and willingness to investigate and prosecute violators of the FCPA. As the potential for bribery increases, it is imperative that companies design and implement an effective compliance policy.
Some companies, however, have increased compliance salaries without addressing the need to utilize a robust FCPA compliance policy. These are the types of companies that federal agencies tend to investigate for FCPA violations.
This only further emphasizes the need to secure a team of FCPA defense attorneys as soon as possible to advise you on these new developments.
At Oberheiden, P.C., our attorneys include former FBI agents, former U.S. attorneys, and former prosecutors, all ready to advise you on your compliance policy and how evolving trends in compliance salary and jobs can impact your current strategy.
Do not wait to get in touch with a qualified defense attorney today. Put Oberheiden, P.C. on your side to fight for your freedom and company.
Introduction to the Foreign Corrupt Practices Act and Its Role on Company Compliance Policies
The Foreign Corrupt Practices Act (“FCPA”) was enacted in 1977 and contains two important sections: (1) the antibribery provisions and (2) the accounting and recordkeeping provisions.
Briefly, the FCPA prohibits individuals and companies from bribing foreign officials to obtain or retain business. It also requires companies to maintain adequate books, records, and internal controls throughout their accounting practices.
The Act imposes civil and criminal penalties for the failure to comply with its provisions. Federal enforcers of the FCPA — the SEC and the DOJ — have signaled their intent to increase investigations and prosecutions while expecting companies to strengthen their FCPA compliance policies.
FCPA compliance controls within a company are designed to demonstrate compliance with anti-corruption legislation and create a work environment where bribery is prohibited and should instead be identified and promptly remedied.
FCPA Compliance Jobs
There are a multitude of jobs in FCPA compliance or jobs that encompass some compliance or anti-corruption duties.
Below we provide several examples with summaries of the job descriptions:
- Anti-Corruption Program Advisor / Anti-Corruption Advisor:Anti-corruption advisors provide guidance on a company’s anti-corruption policies and design and implement anti-corruption reform.
- Associate General Counsel: This is a legal leadership role that emphasizes planning, executing, and supervising the legal aspects of a company’s business and operational policies. The Associate General Counsel also advises on SEC reporting, transactional work such as M&As or other deals that will require due diligence, and other compliance mechanisms.
- Chief Ethics & Compliance Officer: The individuals holding these jobs are responsible for monitoring and overseeing instances of misconduct made through a company’s reporting mechanism or whistleblower program on suspected corruption. The Chief Ethics & Compliance Officer makes sure that all complaints are addressed internally and promptly.
- Senior Director of Ethics & Compliance: The Senior Director manages and oversees the company’s ethics and compliance program. This role generally entails the execution of a revised compliance policy focused on anti-corruption, ethics, third parties, and FCPA compliance.
- Manager of Ethics & Compliance: The Manager handles day-to-day operations of a company’s compliance program and works on multiple aspects of compliance including communications, personnel training, risk assessment and mitigation, and investigations. The Manager reports to the Chief Ethics & Compliance Officer.
- Integrity Officer: The Integrity Officer assists with implementing the code of conduct within the company and subsequently with handling suspected FCPA violations. These officers play a key role in monitoring and organizing the company’s integrity systems.
General Compliance Roles
- Vice President of Compliance: The VP of Compliance is a high position and is responsible for managing company compliance programs in many related areas such as gifts and entertainment, political compliance, FCPA, and anti-money laundering.
- Corporate Compliance Counsel: This counsel position requires an in-depth understanding of compliance policies with an increased emphasis on specialized and high-risk compliance areas such as third parties, transactions with foreign officials, and whistleblowing.
- Anti-Bribery and Anti-Corruption Manager: This managerial position supports the company’s anti-bribery and anti-corruption compliance programs. The individual holding this role is responsible for providing compliance guidance that supports the company’s operational goals and is also responsible for making sure that such guidance is consistent with federal guidance.
- Staff Compliance: Staff positions are critical for the proper operation of a company’s compliance policies. These positions involve interaction of company personnel at all levels and requires that the job holder work to enhance the compliance program of the company using a risk-based and continuous monitoring approach.
FCPA Compliance Salary
Examples of Compliance Salaries
The FCPA Blog discussed information reported in a French financial newspaper that studied compliance job trends in 2018. The Blog notes that FCPA compliance salaries are on a steady increase.
For instance, over 50% of compliance professionals are earning more than $80,000 gross per year.
Salary ranges also vary significantly depending on the years of experience that the potential compliance job applicant offers. For instance, compliance lawyers with five to ten years’ experience can expect a gross annual salary of between about $60,000 to $90,000.
Those individuals who have attained over ten years’ experience will see their potential salary rise to over a gross annual $125,000.
Further, a managerial compliance function can earn anywhere between about $130,000 to $170,000 gross per year.
Reasons for the Increase in Compliance Salary
A plausible explanation that has been observed is the increase in risk that must be undertaken by compliance professionals.
Compliance jobs are far from risk averse. In fact, as federal agency efforts to ramp up investigations and prosecutions of companies suspected of engaging in suspicious behavior continues, compliance jobs will become more risk-intensive.
To counteract the heightened risks, companies are increasing the salary potential of prospective compliance applicants. But there is a risk in doing this.
The risk in offering higher salaries for compliance salaries occurs when those companies do not understand the need to revitalize or re-develop an effective compliance policy that supports a corporate culture of anti-corruption and anti-bribery.
It is critical for companies to understand that with an increase in both federal prosecutions of compliance officers and compliance salaries comes the need to re-design a company’s compliance policy to account for new risks, detect warning signs promptly, and rectify uncovered instances of corruption—all while accommodating the company’s business needs in an evolving market.
Need Advice About FCPA Compliance Jobs and Salary?
FCPA can impose significant penalties and imprisonment terms on those expected to have violated its provisions.
Companies engaging in suspicious instances of corruption or bribery can expect an intensified degree of federal government scrutiny since the DOJ and SEC have expressed their intent to increase investigations and prosecutions.
Despite any increases in compliance jobs or compensation, it is imperative now more than ever to develop and maintain a robust compliance policy.
If you have questions on FCPA compliance policies, contact a FCPA defense attorney.
At Oberheiden, P.C., we have a well-qualified team of FCPA attorneys that can provide legal advice to you regarding recent trends in compliance jobs and salary and how this affects your compliance policy.
Call us today or contact our office for a free consultation.