The challenges of wearing multiple hats: A compliance officer’s guide to successfully leading a small firm
Abstract
This paper delves into the multifaceted role of chief compliance officers (CCOs) in small financial services firms, emphasising the heightened challenges and unique dynamics they face. Unlike their counterparts in larger organisations, CCOs in small firms must navigate limited resources, expanded responsibilities and a complex regulatory landscape, often juggling roles in compliance, risk management, cybersecurity and legal matters. The absence of specialised teams and advanced tools requires small firm CCOs to adopt innovative, resourceful approaches to meet regulatory demands and safeguard their firms’ reputations. Key topics explored include the broad scope of responsibilities, the impact of resource constraints and the challenge of balancing competing priorities while maintaining a strong culture of compliance. This paper highlights practical strategies for small firms, such as leveraging cost-effective tools, fostering leadership buy-in and utilising creative training and communication methods. In addition, it addresses the personal toll of the role, with insights on managing stress, achieving work–life balance and navigating the evolving regulatory environment. Recent regulatory guidance from Financial Industry Regulatory Authority, Inc. (FINRA) and calls for clearer frameworks by the Securities and Exchange Commission (SEC) regarding CCO liability are examined, providing reassurance to compliance professionals about their responsibilities and protections. Ultimately, this paper underscores the critical contributions of small firm CCOs to the financial industry, advocating for greater support, recognition and strategic investment in compliance as a cornerstone of organisational trust, integrity and long-term success. This article is included in The Business and Management Collection (https://hstalks.com/business/).
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Author's Biography
Steven D. Trigili , MBA, CAMS, is the Chief Compliance and Anti-Money Laundering Compliance Officer of Garden State Securities, Inc, and Garden State Investment Advisory Services, LLC, an independent, US-based financial services firm servicing institutional and retail customers around the world. With over 30 years of experience in executive-level compliance and risk management in financial services, Steven oversees Garden State’s entire global compliance programme. He is directly responsible for the firm’s risk management and antimoney-laundering programmes, and he also leads the firm’s cybersecurity and safeguarding initiatives. In addition to these responsibilities, he plays a key role in developing and implementing firm-wide policies to ensure compliance with evolving regulatory requirements and industry best practices. Before joining Garden State in 2010, he served as the Chief Compliance Officer (CCO) for a boutique Wall Street-based global investment and wealth management firm. Steven is currently serving a third term on the Financial Industry Regulatory Authority, Inc. (FINRA) Regional Committee, and he also serves on the FINRA Continuing Education Content Committee, where he assists in writing content for regulatory exams and new continuing education courses. A featured speaker at industry conferences abroad for over 20 years, Steven also provides consulting and expert witness services to investment advisors and their counsel. Steven is also an adjunct professor of business and management at the Master’s Degree programmes of Georgian Court University, Northern State University and Southern New Hampshire University, and he serves on the Editorial Board of the Journal of Financial Compliance.
