
Are you listening? Wisdom from Hui Chen
Compliance professionals do not listen enough. Real insight comes from being in the field—talking with people, observing behavior, and understanding how decisions are made. Data matters, but it is not
One of the most valuable features of PLI’s Compliance & Ethics conferences is something that doesn’t appear on the agenda: the real-time exchange of practice pointers, experience, and data among the professionals in the room. Through live polling across two days of programming, attendees answer questions about various aspects of their programs, including how they’re structured, resourced, and implemented. In doing so, we all contribute to a collective picture of the field that none of us could construct alone.
That willingness to share is not incidental to the work of compliance. It reflects two principles deeply embedded in the culture of this profession: a genuine desire to share what is working in our programs and an understanding that raising practice standards across the board ultimately serves the mission each of us is trying to advance.
The polling from last October’s Advanced C&E Conference produced data on a range of program design questions, including the role and positioning of compliance professionals who work outside headquarters, in regions or business units. We’re speaking here about dedicated compliance professionals working in the field or within business units – not part-time compliance champions or liaisons with compliance responsibilities layered onto their other roles. How these roles are structured, supported, and situated within the organization has meaningful implications for program effectiveness and for the experience of the people doing the work.
Organizations That Have Regional C&E Personnel – and Those That that Wish They Did
When attendees were asked about the reporting relationship for C&E personnel located outside headquarters, the responses broke along four lines. Roughly 46 percent said their regional C&E personnel report directly to the Compliance & Ethics function with a dotted line to the business. Fifteen percent said the reverse: their field personnel report to the business with a dotted line to C&E. Thirteen percent indicated a different arrangement than either of those. And 26 percent – more than one in four – selected the following option: “We WISH we had regional C&E personnel.”
That last figure is worth pausing on. A quarter of the compliance professionals in the room are operating without any dedicated field presence at all, not because they don’t see the value, but because the resources or organizational will are not there. That finding is consistent with responses to a separate question asking what is most important to ensuring an effective compliance program: 26 percent of attendees identified “sufficient resources dedicated to the Compliance & Ethics function” as the single most important factor – the highest-ranked response among all options.

Taken together, these findings tell a coherent story. Field personnel are widely recognized as important. Resources to support them are understood to matter. And yet a significant segment of programs still lacks a dedicated regional presence.
The Structural Question
For organizations that do have regional C&E personnel, the reporting relationship matters – for program integrity, for the role that regional professionals play in the program, and for the quality of their professional lives. A solid-line-to-C&E structure gives field compliance personnel a clearer path to independence and a more direct connection to program standards, training, and oversight. A business-reporting structure, while not inherently problematic, can create more friction around independence and can complicate the field professional’s ability to escalate concerns or resist business pressure.
Those reporting relationships don’t exist in a vacuum. The broader positioning of the C&E function matters too. Survey data shows that 34 percent of attendees said their compliance function sits within the General Counsel’s office with C&E as the CCO’s only role. Roughly 18 percent said that C&E reports through a member of the legal department who reports to the General Counsel. Another 24 percent report directly to the CEO or Board in a standalone structure. These structural realities inevitably shape the experience of field personnel.

Supporting People in the Field
Regional compliance personnel often operate with less visibility, less proximity to resources, and less day-to-day connection to the central compliance function than their headquarters counterparts. They may be the only compliance voice in a particular geography, responsible for translating the program into a local context while fielding questions, managing relationships with business leadership, and handling concerns that arise on the ground. The professional isolation this can create is real, even in organizations with robust central programs.
What can compliance leaders do to support field personnel more effectively? Several practical approaches emerged from the conversations at PLI:
Integration is more than org chart placement. Whether field compliance personnel report solidly to C&E or to the business, deliberate connection to the central function makes a difference. Regular touchpoints through structured meetings, shared communications, and involvement in program development help field professionals stay current and feel part of something larger than their individual geography. Where resources permit, in-person meetings for the entire compliance team can make an enormous difference in the sense of connection regional personnel feel.
Calibration matters. Field personnel benefit from understanding how the organization’s risk priorities translate into their specific context. A regional compliance professional in an emerging market jurisdiction faces a different compliance environment than one in a lower-risk domestic operation. Giving field personnel the analytical tools and organizational context to make those judgments builds both competence and confidence. Just as important, guidance from headquarters should support – not displace – regional authority and decision-making. When local compliance is sidelined by excessive HQ approval requirements, the program can suffer, and the regional professional’s relationship with the business can be weakened.
Visibility within the region is critical. When senior compliance and business leadership acknowledge and actively support regional compliance personnel, it changes the professional’s standing within the local context. Field compliance professionals who are seen as having real organizational backing are better positioned to do the work effectively. In practice, this may include requiring regional compliance leadership to sit on regional leadership teams, integrating local compliance into acquisition planning, and ensuring that business leaders understand the role and authority of the regional compliance function.
Document the role. In one program assessment conducted for a multinational company recently, the regional compliance officers in most regions were highly capable and had worked their way into positions of strategic importance. That was excellent, of course, but it became clear that their standing was hard-earned and – to some extent – a happy coincidence of the particular individuals in those roles. The expectations and authority of the regional compliance function were not documented. In a region with a less experienced compliance professional, the role suffered accordingly. The authority, responsibilities, escalation rights, and independence of regional compliance personnel need to be documented beyond a straight or dotted reporting line to corporate.
The Value of Knowing Where We Stand
The willingness of PLI attendees to share their data and stories – including data and stories that reveal gaps and aspirations – is one of the most valuable aspects of a program like this. Compliance is a profession in which knowing what peers are doing, and how their decisions are working in practice, is genuinely useful. Benchmarking is not just an academic exercise; it informs resource conversations, validates structural choices, and sometimes surfaces problems that an individual practitioner assumed were unique to their organization.
The picture that emerges from last year’s data on regional compliance personnel is neither uniformly encouraging nor discouraging. Nearly half of organizations with field presence have structured it in a way that supports independence. A meaningful share have not yet resolved the structural question or have not yet achieved any field presence at all. And a substantial percentage identified resources as the core issue, which, in the context of regional compliance personnel, is often exactly right.
What the data makes clear is that regional compliance roles are not simply an extension of the org chart. They are a test of how effectively a compliance program reaches the business, supports its people, and translates standards into practice across the organization. The more we understand how these roles are structured and supported, the better positioned we are to strengthen them.
PLI’s upcoming 2026 C&E Essentials conference promises to build on these insights with more real-time peer benchmarking. I hope you can join us in the room to be part of the conversation.
For more information about and to register for PLI’s Compliance & Ethics Essentials 2026 program (June 4-5, 2026, in NYC and virtual), visit https://www.pli.edu/programs/compliance–ethics-essentials/442255
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