The First 90 Days with an Outsourced Chief Compliance Officer: What to Expect

Bringing in an outsourced Chief Compliance Officer (CCO) is a strategic move for businesses in highly regulated industries such as financial services, fintech, healthcare, and private equity. Whether your company is facing regulatory scrutiny, expanding operations, or simply tightening compliance protocols, an outsourced CCO provides the expertise needed without the overhead of a full-time hire.

But what should you expect in the first 90 days after onboarding an outsourced CCO? This period is crucial for assessing risks, establishing compliance frameworks, and ensuring your company is positioned to meet regulatory requirements. Here’s what the timeline typically looks like.

Days 1-30: Assessment & Immediate Risk Mitigation

The first month focuses on understanding your business, identifying immediate compliance risks, and establishing priorities.

Key Activities:

✅ Compliance Risk Assessment – The outsourced CCO will conduct a comprehensive review of your company’s existing compliance framework, policies, and procedures. This may include:

• Reviewing internal controls and governance structures.

• Identifying gaps in regulatory compliance (e.g., SEC, AML/KYC, data privacy laws).

• Assessing past compliance audits, regulatory filings, and incident reports.

✅ Regulatory Filings & Urgent Compliance Needs – If your company is due for a regulatory filing, facing an audit, or dealing with unresolved compliance issues, your outsourced CCO will address these immediate concerns first.

✅ Stakeholder Interviews & Business Understanding – Your CCO will meet with key stakeholders such as the executive team, legal counsel, and operations leads to understand:

• Business objectives and risk appetite.

• Compliance pain points and historical challenges.

• Investor or regulatory expectations.

✅ Initial Training & Culture Assessment – A strong compliance program isn’t just about policies—it’s about company culture. Your outsourced CCO may conduct preliminary compliance awareness training for employees to gauge the current level of compliance understanding.

✅ Drafting a Compliance Roadmap – By the end of the first month, you should have a clear, high-level plan outlining:

• Priority compliance areas that need immediate attention.

• Medium- and long-term compliance goals.

• The compliance program’s structure and key policies to be implemented.

Days 31-60: Implementation & Compliance Integration

After identifying gaps and creating a roadmap, the next 30 days focus on developing compliance policies, implementing risk controls, and strengthening reporting structures.

Key Activities:

✅ Policy Development & Updates – Your CCO will draft, review, or update policies related to:

• AML/KYC procedures (for financial and fintech firms).

• Data privacy (GDPR, CCPA, HIPAA, etc.).

• SEC/FINRA compliance for investment firms.

• Vendor and third-party risk management.

✅ Internal Compliance Controls & Reporting – Your CCO will establish reporting mechanisms to ensure compliance violations are detected and addressed. This may include:

• Creating an internal audit and compliance monitoring process.

• Implementing whistleblower protections and confidential reporting.

• Standardizing compliance documentation for future audits and regulatory reviews.

✅ Employee & Leadership Compliance Training – The outsourced CCO will conduct structured compliance training tailored to different departments, ensuring that:

• Employees understand compliance obligations.

• The executive team is aligned on regulatory risks.

• Compliance reporting and escalation procedures are clear.

✅ Regulatory Engagement & External Communication – If your company is subject to regulatory oversight, your CCO may initiate discussions with regulators, auditors, or external compliance consultants to ensure proactive compliance.

Days 61-90: Optimization & Compliance Sustainability

The final 30 days focus on solidifying compliance practices, refining policies, and creating long-term compliance sustainability.

Key Activities:

✅ Compliance Testing & Mock Audits – Your CCO may conduct mock regulatory audits to ensure your company is prepared for actual inspections. This can include:

• Reviewing transaction monitoring systems (for financial institutions).

• Ensuring data security and privacy measures are functioning properly.

• Testing reporting frameworks for compliance violations.

✅ Finalizing the Compliance Playbook – Your outsourced CCO will provide a detailed compliance handbook outlining:

• Policies and procedures for key compliance areas.

• Risk mitigation strategies.

• A compliance escalation plan.

• Roles and responsibilities of employees in ensuring compliance.

✅ Ongoing Compliance Strategy & Future Roadmap – Before the 90-day mark, your CCO will present a long-term compliance strategy to leadership. This roadmap ensures compliance isn’t just a one-time fix but a scalable, ongoing process.

✅ Determining Long-Term Compliance Needs – At this stage, your company will decide:

• If ongoing outsourced CCO services are needed.

• Whether to transition to an in-house compliance team.

• The level of support required for continued compliance monitoring.

Key Takeaways

• The first 90 days with an outsourced CCO are critical for identifying risks, setting up compliance frameworks, and aligning policies with regulatory expectations.

• The initial month focuses on risk assessment and addressing immediate compliance issues.

• By 60 days, compliance policies should be integrated into daily operations, with staff trained and reporting mechanisms in place.

• By 90 days, a sustainable compliance strategy should be finalized, ensuring the company is prepared for audits, regulatory filings, and long-term risk management.

Conclusion

Hiring an outsourced Chief Compliance Officer is a smart move for companies looking to stay ahead of regulatory changes while keeping costs manageable. The first 90 days set the foundation for a strong, sustainable compliance culture that reduces risk and increases investor confidence.

Whether your company is preparing for SEC registration, AML compliance, or ESG reporting, an outsourced CCO provides the expertise and flexibility needed to navigate regulatory challenges while allowing leadership to focus on business growth.

If your company is considering outsourcing compliance leadership, ensure you have a structured 90-day plan to maximize the benefits and establish a solid compliance framework from day one.