The Importance of Correctly Assigning Roles & Responsibilities in a Compliance Team

Introduction: Compliance Does Not Fail Because of Bad Intentions

Most compliance failures do not arise because an organisation set out to ignore the law. They arise because no one was clearly responsible.

When regulators investigate misconduct, the story is almost always the same:

◼️“We thought someone else owned that.”

◼️“It sat between Legal and Compliance.”

◼️“The policy existed, but it wasn’t operationalised.”

◼️“The team was stretched, and priorities weren’t clear.”

At the centre of these failures is not a missing policy, inadequate training, or lack of technology.
It is poorly designed roles and responsibilities.

In a compliance function, how roles and responsibilities are assigned determines the actual level of coverage, the quality of oversight, and the speed at which issues are identified and addressed. This is not a theoretical concern. It is the difference between a compliance function that performs under scrutiny and one that collapses when tested.

This article explores why assigning roles and responsibilities correctly is one of the most important — and most underestimated — design decisions in any compliance team.

Compliance Is an Accountability Function, Not a Paper Function

Compliance is often misunderstood as a documentation exercise: policies, procedures, training records, attestations. These artefacts matter, but they are not the function itself.

At its core, compliance is an accountability system.

Every regulatory obligation must be:

◼️understood,

◼️owned,

◼️monitored,

◼️escalated,

◼️and defended.

None of that happens without people. And people only act when:

◼️responsibility is clear,

◼️authority is explicit,

◼️and accountability is enforced.

A compliance function with excellent policies but weak role design will always underperform. Conversely, a well-designed team with clear responsibilities can often operate effectively even with imperfect documentation.

Why Roles & Responsibilities Matter More in Compliance Than Other Functions

All teams need role clarity. Compliance teams depend on it.

There are three structural reasons for this:

1. Compliance Risk Is Silent Until It Isn’t

Unlike sales or operations, compliance failure does not announce itself early. Breaches often sit unnoticed until:

◼️a whistleblower speaks up,

◼️a regulator asks questions,

◼️or a crisis forces disclosure.

If roles are unclear, issues simply drift.

2. Compliance Is Judged Retrospectively

When regulators investigate, they look backwards:

◼️Who knew?

◼️Who should have known?

◼️Who was responsible?

◼️Why wasn’t action taken?

◼️At that point, vague role descriptions and shared responsibility offer no protection.

3. Compliance Sits Across the Business

Compliance touches procurement, sales, HR, finance, operations, and leadership. Without precise role allocation, compliance becomes everyone’s job — which in practice means no one’s job.

The Core Principle: One Obligation, One Owner

The most important rule in compliance role design is deceptively simple:

Every material compliance obligation must have a single, named owner.

This does not mean:

◼️one person does all the work,

◼️or that execution cannot be delegated.

It means:

◼️accountability is personal,

◼️escalation paths are clear,

◼️and ownership cannot be avoided.

When organisations move away from this principle, three predictable problems arise:

◼️risks fall between roles,

◼️accountability becomes diluted,

◼️decision-making slows or stops entirely.

Shared responsibility may sound collaborative, but in compliance it is usually a warning sign.

Distinguishing Roles from Responsibilities (and Why It Matters)

One of the most common design failures in compliance teams is the failure to distinguish roles from responsibilities.

◼️Roles define mandate, authority, and position within the governance structure.

◼️Responsibilities define specific obligations, outputs, and decisions.

For example:

◼️A “Compliance Manager” role may exist.

◼️But unless responsibilities are clearly defined — policy ownership, monitoring scope, escalation thresholds — the role remains vague and ineffective.

High-performing compliance teams:

◼️define roles deliberately,

◼️map responsibilities precisely,

◼️and document how responsibilities move between roles.

This clarity is not bureaucracy. It is operational discipline.

Segmentation: Why Compliance Responsibilities Must Be Split

Another structural failure occurs when organisations try to do too much with too few roles.

Compliance responsibilities fall into fundamentally different categories, each requiring different skills, incentives, and authority. At a minimum, responsibilities should be segmented across the following areas:

Policy Ownership

Someone must:

◼️own each compliance policy,

◼️track regulatory changes,

◼️initiate updates,

◼️and defend policy choices.

Without named ownership, policies become static documents detached from regulation.

Advisory & Interpretation

Grey areas are inevitable. Someone must be responsible for:

◼️interpreting regulation,

◼️advising the business,

◼️making judgment calls,

◼️and escalating issues of principle.

This role requires experience and confidence — not just technical knowledge.

Monitoring & Assurance

Monitoring cannot be optional or informal. Responsibilities must cover:

◼️testing compliance,

◼️identifying exceptions,

◼️documenting findings,

◼️and ensuring remediation.

When advisory and monitoring roles are collapsed, independence disappears.

Investigations & Breach Response

When something goes wrong:

◼️Who initiates the investigation?

◼️Who controls scope?

◼️Who determines findings?

◼️Who signs off remediation?

If these responsibilities are unclear, response will be slow, inconsistent, and legally risky.

Regulatory Engagement

Regulators expect discipline. Responsibilities must clearly define:

◼️who communicates with regulators,

◼️who approves disclosures,

◼️who controls information flow,

◼️and who speaks on behalf of the organisation.

Ad-hoc regulator engagement is one of the fastest ways to lose credibility.

Authority: Responsibility Without Power Is Fiction

Assigning responsibility without authority is one of the most damaging mistakes in compliance design.

If a compliance team member:

◼️cannot stop a transaction,

◼️cannot escalate issues,

◼️cannot access decision-makers,

◼️or fears retaliation,

◼️then responsibility is meaningless.

A functioning compliance team requires:

◼️defined decision rights,

◼️clear escalation thresholds,

◼️and explicit “stop-the-line” authority in high-risk scenarios.

Regulators increasingly focus on this point. They do not just ask who was responsible - they ask whether that person was empowered to act.

Interfaces with Legal, Risk & Audit: Where Most Gaps Occur

Compliance rarely fails in isolation. It fails at the seams.

Poorly defined interfaces between:

◼️Legal and Compliance,

◼️Compliance and Risk,

◼️Compliance and Internal Audit,

◼️create duplication, confusion, or - worse - gaps.

Roles and responsibilities must clearly answer questions such as:

◼️Who owns legal interpretation vs regulatory interpretation?

◼️Who sets risk appetite vs monitors compliance?

◼️Who tests controls vs who remediates failures?

These boundaries must be explicit, documented, and understood across functions.

Capability Matters: Matching Responsibility to Experience

Another frequent failure is assigning responsibilities based on availability rather than capability.

Not all compliance tasks are equal. Some require:

◼️technical execution,

◼️others require judgment under pressure,

◼️others require senior-level influence.

High-risk responsibilities assigned to junior or overstretched staff are a structural weakness, not a resourcing issue.

Effective role design ensures:

◼️senior judgment sits where risk is highest,

◼️execution tasks are appropriately delegated,

◼️and escalation pathways exist when complexity exceeds capability.

Geographic Reality: Compliance Must Follow the Business

Global compliance teams often look neat on paper and dysfunctional in practice.

Responsibilities must reflect:

◼️where the business actually operates,

◼️local regulatory nuance,

◼️language and cultural factors,

◼️and enforcement risk by jurisdiction.

A single “global compliance owner” without local responsibility mapping is not credible in front of regulators.

Effective teams design:

◼️local responsibility,

◼️regional oversight,

◼️and central governance - with clarity at each level.

Accountability, Measurement & Consequences

Assigning responsibilities is meaningless unless accountability follows.

This includes:

◼️performance measurement aligned to compliance outcomes,

◼️independence from revenue incentives,

◼️and real consequences when responsibilities are not discharged.

Regulators increasingly examine:

◼️how compliance staff are evaluated,

◼️whether failures have consequences,

◼️and whether incentives undermine independence.

Compliance cannot function where responsibility exists only on paper.

Documentation: Defensibility Is Not Optional

Finally, roles and responsibilities must be:

◼️documented,

◼️current,

◼️and evidenced in practice.

When regulators arrive, this is one of the first areas examined.

They do not just want to see:

◼️role descriptions,

◼️org charts,

◼️or RACI matrices.

They want to see:

◼️that people understand their responsibilities,

◼️that responsibilities are exercised,

◼️and that accountability is real.

What “Good” Looks Like

A compliance team with well-designed roles and responsibilities:

◼️identifies issues earlier,

◼️escalates faster,

◼️avoids duplication,

◼️withstands scrutiny,

◼️and earns trust from both regulators and the business.

It does not feel bureaucratic. It feels decisive.

Final Thought: Compliance Is Built on People, Not Policies

Policies set intent.
Systems enable scale.
Roles and responsibilities determine outcomes.

If you want a compliance team that genuinely fires — rather than one that merely exists — start with role design. Everything else depends on it.