The Five Pitfalls a New Chief Compliance Officer Should Avoid in the First 3 Months

Thursday, 23/10/2025 | 13:49 GMT by Jamie Hoyle
  • New CCOs must listen, build trust, and collaborate, not enforce compliance alone, to achieve success.
  • Technology is mission-critical because manual processes overwhelm compliance teams; rigid or lax approaches reduce effectiveness.
CCO first 90 days

Starting as a new Chief Compliance Officer is like being handed the keys to a complex machine that’s already running at full speed—though perhaps in the wrong direction.

You must quickly learn how every part functions, identify what needs fixing, and adjust course without shutting down the operation or losing momentum. The pressure is immediate, and a single misstep can undermine months of relationship-building.

Those first 90 days don’t just shape your compliance program—they define how the entire organization views compliance itself. Move too fast, too rigidly, or without context, and you risk being labeled as the “department of no” before you’ve even earned a seat at the table.

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Through conversations with experienced CCOs across advisory, private equity, and asset management firms, five recurring pitfalls emerge—each with lessons from those who’ve learned to navigate them effectively.

Pitfall #1: Racing to Make Changes Without Understanding the Business

The urge to take immediate action is strong. After all, you were hired to strengthen compliance . But diving into audits, rewriting policies, or replacing systems before understanding how the business truly operates is the fastest route to confusion and resistance.

Every firm has its own informal hierarchies, communication habits, and cultural norms. Failing to grasp these can turn well-intended reforms into operational bottlenecks—or worse, alienate the very people whose cooperation you need.

Source: FCA
Source: FCA

The fix: Slow down and listen first. Spend the first month observing how things actually get done. Understand who the key influencers are and what the existing compliance culture looks like. The goal isn’t to delay action—it’s to ensure that when you act, it’s aligned with the business reality you’re stepping into.

Pitfall #2: Treating Compliance as a Solo Mission

Compliance may sit under your name, but it can’t succeed in isolation. Some new CCOs focus solely on crafting impeccable policies or perfecting oversight frameworks while overlooking the human side—relationship-building, trust, and internal advocacy.

Without allies, compliance becomes something people tolerate rather than support. The absence of buy-in ensures that even the most robust program will struggle in practice.

The fix: Frame compliance as partnership, not policing. Build early credibility by helping other teams achieve their goals safely. As one CCO put it, “It always circles back to taking care of our clients.” When people see compliance as essential to that shared mission, cooperation follows naturally.

Pitfall #3: Assuming What Worked Before Will Work Again

Each firm is a unique ecosystem. Strategies that worked in your previous role might not translate to the new one. Relying on old playbooks can blind you to specific risks or cultural nuances that require fresh thinking.

CCO

Compliance is inherently adaptive—it must evolve alongside shifting regulations, technologies, and business models. Bringing a rigid mindset into a dynamic environment risks both oversight gaps and missed opportunities.

The fix: Stay curious and flexible. Use your experience as a guide, not a template. Ask open questions, test assumptions, and look for blind spots. The best compliance programs are not imported—they’re built, layer by layer, to fit the contours of each organization.

Pitfall #4: Overlooking the Technology Foundation

Manual monitoring and fragmented systems can quickly overwhelm even the most capable compliance teams. Yet, many CCOs delay technology assessments, seeing them as secondary to “more urgent” tasks.

That’s a costly mistake. Firms today manage sprawling communication networks—Slack, WhatsApp, Teams, Signal, text, social media, and more. Without integrated surveillance and automation tools, data review becomes unmanageable, and critical red flags can slip through.

The fix: Make technology evaluation a Day 1 priority. Whether it’s automated supervision, intelligent risk detection, or unified message capture, the right systems multiply your effectiveness. They free up bandwidth for strategic oversight instead of manual firefighting.

Pitfall #5: Swinging Too Far Toward Either Extreme

It’s easy to overcorrect—either by enforcing rigid rules that choke productivity or by being overly lenient to avoid friction. Both extremes create long-term vulnerabilities.

The best compliance leaders understand that control and flexibility aren’t opposites; they coexist. Sustainable compliance frameworks protect the firm while supporting its people and goals.

The fix: Find balance. Strong oversight doesn’t have to mean red tape. The aim is not to slow the business down, but to ensure it can move forward safely. Compliance should be an enabler of growth, not a barrier to it.

The Path Forward

These pitfalls are not inevitable. The CCOs who thrive share key traits: they listen before acting, collaborate instead of dictating, tailor strategies to their environment, invest in technology early, and keep the bigger purpose in view.

Ultimately, compliance leadership isn’t about policy enforcement—it’s about cultural transformation. Your first 90 days are your chance to set that tone, to demonstrate that compliance can be both strategic and supportive.

As regulations tighten and technologies evolve, the complexity will only increase. But the mission remains the same: building a culture where compliance strengthens, rather than hinders, business success.

Starting as a new Chief Compliance Officer is like being handed the keys to a complex machine that’s already running at full speed—though perhaps in the wrong direction.

You must quickly learn how every part functions, identify what needs fixing, and adjust course without shutting down the operation or losing momentum. The pressure is immediate, and a single misstep can undermine months of relationship-building.

Those first 90 days don’t just shape your compliance program—they define how the entire organization views compliance itself. Move too fast, too rigidly, or without context, and you risk being labeled as the “department of no” before you’ve even earned a seat at the table.

Join IG, CMC, and Robinhood in London’s leading trading industry event!

Through conversations with experienced CCOs across advisory, private equity, and asset management firms, five recurring pitfalls emerge—each with lessons from those who’ve learned to navigate them effectively.

Pitfall #1: Racing to Make Changes Without Understanding the Business

The urge to take immediate action is strong. After all, you were hired to strengthen compliance . But diving into audits, rewriting policies, or replacing systems before understanding how the business truly operates is the fastest route to confusion and resistance.

Every firm has its own informal hierarchies, communication habits, and cultural norms. Failing to grasp these can turn well-intended reforms into operational bottlenecks—or worse, alienate the very people whose cooperation you need.

Source: FCA
Source: FCA

The fix: Slow down and listen first. Spend the first month observing how things actually get done. Understand who the key influencers are and what the existing compliance culture looks like. The goal isn’t to delay action—it’s to ensure that when you act, it’s aligned with the business reality you’re stepping into.

Pitfall #2: Treating Compliance as a Solo Mission

Compliance may sit under your name, but it can’t succeed in isolation. Some new CCOs focus solely on crafting impeccable policies or perfecting oversight frameworks while overlooking the human side—relationship-building, trust, and internal advocacy.

Without allies, compliance becomes something people tolerate rather than support. The absence of buy-in ensures that even the most robust program will struggle in practice.

The fix: Frame compliance as partnership, not policing. Build early credibility by helping other teams achieve their goals safely. As one CCO put it, “It always circles back to taking care of our clients.” When people see compliance as essential to that shared mission, cooperation follows naturally.

Pitfall #3: Assuming What Worked Before Will Work Again

Each firm is a unique ecosystem. Strategies that worked in your previous role might not translate to the new one. Relying on old playbooks can blind you to specific risks or cultural nuances that require fresh thinking.

CCO

Compliance is inherently adaptive—it must evolve alongside shifting regulations, technologies, and business models. Bringing a rigid mindset into a dynamic environment risks both oversight gaps and missed opportunities.

The fix: Stay curious and flexible. Use your experience as a guide, not a template. Ask open questions, test assumptions, and look for blind spots. The best compliance programs are not imported—they’re built, layer by layer, to fit the contours of each organization.

Pitfall #4: Overlooking the Technology Foundation

Manual monitoring and fragmented systems can quickly overwhelm even the most capable compliance teams. Yet, many CCOs delay technology assessments, seeing them as secondary to “more urgent” tasks.

That’s a costly mistake. Firms today manage sprawling communication networks—Slack, WhatsApp, Teams, Signal, text, social media, and more. Without integrated surveillance and automation tools, data review becomes unmanageable, and critical red flags can slip through.

The fix: Make technology evaluation a Day 1 priority. Whether it’s automated supervision, intelligent risk detection, or unified message capture, the right systems multiply your effectiveness. They free up bandwidth for strategic oversight instead of manual firefighting.

Pitfall #5: Swinging Too Far Toward Either Extreme

It’s easy to overcorrect—either by enforcing rigid rules that choke productivity or by being overly lenient to avoid friction. Both extremes create long-term vulnerabilities.

The best compliance leaders understand that control and flexibility aren’t opposites; they coexist. Sustainable compliance frameworks protect the firm while supporting its people and goals.

The fix: Find balance. Strong oversight doesn’t have to mean red tape. The aim is not to slow the business down, but to ensure it can move forward safely. Compliance should be an enabler of growth, not a barrier to it.

The Path Forward

These pitfalls are not inevitable. The CCOs who thrive share key traits: they listen before acting, collaborate instead of dictating, tailor strategies to their environment, invest in technology early, and keep the bigger purpose in view.

Ultimately, compliance leadership isn’t about policy enforcement—it’s about cultural transformation. Your first 90 days are your chance to set that tone, to demonstrate that compliance can be both strategic and supportive.

As regulations tighten and technologies evolve, the complexity will only increase. But the mission remains the same: building a culture where compliance strengthens, rather than hinders, business success.

About the Author: Jamie Hoyle
Jamie Hoyle
  • 1 Article
About the Author: Jamie Hoyle
Jamie is VP, Product at MirrorWeb where he leads product strategy for the company. He joined MirrorWeb as Lead Software Engineer in 2017, eventually transitioning to Product and spearheading the development of their flagship communications supervision platform, MirrorWeb Insight. In 2024, Jamie relocated to Austin, Texas to embed himself in the heart of the US compliance landscape and stay close to the customers shaping the future of digital communications oversight.
  • 1 Article

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