Case study · Chief compliance officer search

Chief compliance officer search for a NYSE-listed payments company in New York

A NYSE-listed payments company in New York hired a chief compliance officer who reports to its audit committee. Candidates were assessed against the DOJ Evaluation of Corporate Compliance Programs; the shortlist arrived in week 3 and the offer was accepted in week 10.

Brief a CCO search Compliance recruitment

Lorenzo Sartori — Founder, Sartori & Partners Updated October 19, 2026

01 The file

What happened on this chief compliance officer search?

A NYSE-listed payments company in New York retained Sartori & Partners to find its chief compliance officer. The seat reports to the audit committee. Every candidate was assessed against the U.S. Department of Justice Evaluation of Corporate Compliance Programs. The shortlist arrived in week 3 and the offer was accepted in week 10.

The file is one of 36 compliance and regulatory leadership placements (CCO, MLRO, head of sanctions, DPO/CPO) inside 400+ placements since 2017, 230+ of them in-house. It ran on the CCO clock: 21 days to a shortlist and 10 weeks to an accepted offer.

Seat: Chief Compliance Officer, NYSE-listed payments company, New York.
Reporting line: Audit committee.
Assessed against: DOJ Evaluation of Corporate Compliance Programs: design, resources and empowerment, working in practice.
Shortlist: Week 3. CCO clock: 21 days to shortlist, across 36 compliance leadership placements since 2017.
Accepted offer: Week 10. CCO clock: 10 weeks to accepted offer.
Terms: Retained. 25-30% of first-year total compensation, 30% of the fee as retainer, 12-month replacement guarantee.

02 A payments seat

Why is a payments CCO seat different from a bank or corporate CCO?

A payments CCO answers to more supervisors than most corporate compliance officers, and a listed one also answers to an audit committee.

A payments company moves other people's money. That puts its compliance officer under state money-transmission licensing (in New York, the Department of Financial Services), federal anti-money-laundering obligations under the Bank Secrecy Act, and sanctions screening against Treasury's OFAC lists. A NYSE listing adds a second layer: the audit committee and the SEC disclosure regime around it.

So the hire is neither a bank CCO who has never seen a product release cycle nor a corporate compliance lead who has never sat an examination. The seat needs both: someone who could own the examination file and still argue a launch with the product team. Dual-regulated financial services companies typically run 15 to 40 lawyers plus a compliance function.

03 The reporting line

Why did the audit-committee reporting line come before the job description?

The reporting line decides who wins when a revenue product and a control collide. A CCO who reports only through the legal function can be overruled in a deal meeting; a CCO with an audit-committee line takes that disagreement to the board. The reporting line is written into the Mandate Blueprint in week 1, before any candidate is approached. On this file it ran to the audit committee.

Candidates who have run a program with a direct line to a board ask about the reporting line early. The Department of Justice asks the same thing of a company: whether compliance has autonomy, adequate resources and direct access to the board or its audit committee.

04 The ECCP test

How was each CCO candidate assessed against the DOJ ECCP?

The Evaluation of Corporate Compliance Programs asks three questions of a program. The dossiers turned each one into a question about the candidate.

Well designed?

Did the candidate build monitoring that fits a payments product, or copy a bank template onto a payments stack?

Resourced and empowered?

Has the candidate won headcount, systems or data access from a board, and can they show what it changed?

Working in practice?

What did the candidate's last examination find, and what was different in the months after it?

Policy authorship was not the test. Examinations sat as the accountable officer, decisions taken and resources won were. The method is set out on chief compliance officer search and in the buyer guide hiring a chief compliance officer.

05 The clock

How long did the CCO search take, week by week?

Chief compliance officer search, NYSE-listed payments company, New York. Standard retained process and this file's milestones.
Week	Step	This file
1	Mandate Blueprint: reporting line, regulators, scope, pay, conflicts	Reporting line: audit committee.
1-2	Total-market mapping	Standard step.
2-4	Private outreach, blind both ways until interest is mutual	Standard step.
3	Shortlist with assessment dossiers	Delivered in week 3. Each dossier written against the DOJ ECCP.
5-9	Interviews and offer engineering	Standard step.
10	Accepted offer	Offer accepted in week 10.
After start	Closing, notice, onboarding, 90-day check-ins	Standard step.

CCO clock across 36 compliance and regulatory leadership placements since 2017: 21 days to shortlist, 10 weeks to accepted offer. GC/CLO median: 11 weeks across 52 searches.

Source: Sartori & Partners corporate track record, 2017-2026.

06 What this search shows

What should a company hiring a payments CCO take from this file?

Write the reporting line before the competencies. An audit-committee line is what makes the seat credible to a regulator and to the candidates worth hiring.
Assess against the DOJ ECCP: design, resources and empowerment, working in practice. Ask for examinations sat, not policies written.
Plan on the CCO clock: about three weeks to a shortlist and ten to an accepted offer. The CCO median of 10 weeks runs a week shorter than the GC/CLO median of 11 weeks.
Put the fee, the 12-month replacement guarantee and the 24-month off-limits in the letter before outreach.
Judge the hire after it starts. Across placed in-house leaders, 97% remain at 12 months and 91% at 24 months; offer acceptance on corporate mandates is 96%.

External documents this search used

4 references

Another audit committee, the same brief

A CCO who had sat across a regulator

We asked for a CCO who had sat across a regulator, not a policy author. The dossiers named examinations. We interviewed three. We hired one.

Chair of the audit committee Euronext-listed insurer · Brussels

07 Related

Hiring a chief compliance officer: next reads

Compliance recruitment

CCO, MLRO, sanctions and privacy leadership for regulated companies, with the CCO clock and terms.

Open compliance recruitment

Chief compliance officer search

The officer mandate: reporting line, examinations named in the dossier, 12-month replacement guarantee.

Brief a CCO search

Hiring a chief compliance officer

The buyer guide: when to hire, what to test, how long it takes and what it costs.

Read the CCO hiring guide

Compliance recruiters in New York

Chief compliance officer search in New York: regulators, seats, pay and the clock.

Open the New York compliance page

Sanctions and AML seats are on sanctions and AML recruitment. Pay by seat is in chief compliance officer pay, 2026. Other corporate files: GC succession in Boston medtech and head of legal operations in Austin software. All files are on the case studies page.

Payments CCO search: common questions

How long does a chief compliance officer search take for a payments company?

On this NYSE-listed payments file the shortlist arrived in week 3 and the offer was accepted in week 10. Across 36 compliance and regulatory leadership placements since 2017, the Sartori & Partners CCO clock is 21 days to a shortlist and 10 weeks to an accepted offer. The general counsel clock is longer: 11 weeks median across 52 GC/CLO searches.

Should a payments CCO report to the audit committee or to the general counsel?

For a listed payments company, the audit committee is the line that holds when a product launch and a control collide. That was the reporting line on this file. The Department of Justice Evaluation of Corporate Compliance Programs asks whether compliance has autonomy and direct access to the board or its audit committee. See hiring a chief compliance officer.

What does it mean to assess a CCO candidate against the DOJ ECCP?

It means testing the person on the three questions prosecutors ask of a compliance program. Is it well designed, is it adequately resourced and empowered, and does it work in practice? A candidate answers them with examinations sat and decisions taken, not with policies written. The service behind this file is compliance recruitment.

What does a retained CCO search cost?

The fee is 25-30% of the hire's first-year total compensation, with 30% of the fee paid as a retainer at engagement. A retained CCO search carries a 12-month replacement guarantee, and off-limits on the client's legal department run 24 months. Detail is in legal recruitment fees explained.

Set the reporting line first. We bring the examination record.

Retained only: 25-30% of first-year total compensation, 12-month replacement guarantee on a CCO search, terms in the letter before we call anyone.

Brief a confidential search Compliance recruitment

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