Why we wrote How to Be a Chief Compliance Officer, and who it’s really for
By Jennifer Geary and Natalie McManus-Barnett
There is a question that sits at the heart of every compliance programme, rarely asked plainly: what is this function actually for?
Not what it does — the audits, the policies, the training, the regulatory filings. Those are means, not ends. The deeper question is whether compliance, as it is currently practised in most organisations, is genuinely shaping behaviour and protecting people, or whether it is performing the appearance of those things. Whether it is woven into the fabric of how an organisation thinks and operates, or whether it is bolted on at the edges, consulted after the fact, and quietly tolerated as a cost of doing business.
We wrote How to Be a Chief Compliance Officer because we believe the answer to that question matters enormously — and because the profession has, until now, lacked the handbook it deserves.
The gap in the literature
Natalie has spent years as a practitioner – former regulator, chartered accountant, compliance chief of staff at Citibank, Fellow of the International Compliance Association – searching for a book that fits the needs of the senior compliance officer. She found insights scattered across leadership texts, risk management manuals, legal white papers and academic journals. She found notes scribbled in margins and frameworks imparted by managers over decades. She did not find a single, authoritative guide that brought it all together and spoke directly to the reality of the CCO role.
That gap is the origin of this book.
A new moment for compliance
We are writing at an inflection point. AI is transforming every dimension of the compliance function — from how risk is identified and measured, to how monitoring is conducted and how advisers are trained. Geopolitical uncertainty is reshaping regulatory landscapes faster than most programmes can adapt. Deregulation in some markets is creating new complexity even as it removes old requirements. And the cost of compliance, once primarily a concern for heavily regulated sectors like financial services, is now a strategic variable for organisations that have never historically thought of themselves as regulated at all.
In this environment, the compliance officer who stays within a narrow technical remit will be overtaken by events. The profession is demanding something different: leaders who can sit at the board table with authority, translate regulatory complexity into strategic decisions, and position compliance not as a constraint on the business but as a source of competitive advantage, trust and resilience.
This book is written for those leaders — and for the organisations that depend on them.
What the book offers
How to Be a Chief Compliance Officer is built around the Compliance 365 Model — so called because compliance risk management matters every day of the year. It starts with three foundations – Culture, Strategy and Execution. At its core is the IMPACT Wheel, a six-spoke framework that maps the full lifecycle of a compliance programme: Identify, Measure, Protect, Assure, Correct and Tell. Around it sit Five Compliance Pillars — Governance, Operations, Technology, Data and Advisory — the foundational capabilities that enable the Wheel to turn.
Together, they provide a blueprint that any compliance leader can pick up and apply, regardless of organisational complexity, industry or geography.
The book covers the full range of what the modern CCO needs:
- How to articulate the compliance mandate to boards and senior stakeholders
- How culture, the invisible hand behind compliance behaviour, shapes every programme decision
- How to align compliance strategy with organisational purpose and risk appetite
- How to navigate the first 100 days in a new role
- How to make the business case for compliance investment
- How to lead in the age of AI, data and relentless regulatory change
But it is not only a book for those with a formal CCO title. As we argue throughout: in today’s complex regulatory environment, any senior leader is, by stealth or overtly, a compliance leader in practice. The Chief Risk Officer, the General Counsel, the Chief People Officer, the board member who chairs the audit committee – all of them need to understand what good compliance leadership looks like and what it demands.
A note on why this matters now
It is easy to pay lip service to mission statements about doing the right thing. It is far harder to build the strategies, structures and cultures that enable ethical behaviour, hold organisations accountable, and provide the board with the insights it needs to make genuinely sound decisions.
That difficulty — and the tools to address it — is what this book is about.
Compliance is not a necessary inconvenience. At its best, it is the mechanism by which organisations become worthy of the trust placed in them: by customers, by regulators, by the people who work within them, and by the societies they operate in.
We hope this book helps more organisations get there.
How to Be a Chief Compliance Officer will be available at the end of April. Register your interest to review an early copy.
About the authors
Jennifer Geary is a former Managing Director, Chief Operating Officer and Chief Risk Officer with over 25 years of experience across financial services, technology, risk and legal. She is a five-time author, speaker, board adviser and Honorary Visiting Fellow at Bayes Business School.
Natalie McManus-Barnett is Managing Director of Innovate Compliance and a former compliance chief of staff at Citibank and ex-regulator for the Financial Conduct Authority. She is a Fellow of the International Compliance Association and a Fellow of the ACCA, and holds degrees from Oxford, and in Law and Applied Accounting.
