The Personal Side of Being a CCO · 05

A CCO Must Sometimes Be Comfortable Being Unpopular

Independence is not measured by how often you say no. It is tested when the answer matters.

By Micheal Sheehy · 5 min read · July 2026

A Chief Compliance Officer who needs to be liked by everyone will eventually make a decision for the wrong reason.

The role sits inside a company, not outside it. A good CCO understands the business, wants it to grow and should help find responsible ways forward. But there are moments when the commercially attractive answer and the responsible answer do not align.

In those moments, the room may not thank you.

Unpopular is not the objective

Some compliance leaders wear obstruction as proof of independence. I do not. Saying no without understanding the business is easy. Designing a safer yes can be much harder.

The CCO’s responsibility is to distinguish risk, explain it clearly and define the conditions under which the organization can proceed. A refusal should be based on evidence, appetite and obligation—not instinct, status or the pleasure of being the person with the red pen.

The goal is not to be the most cautious voice in the room. It is to be the voice the room can trust when caution is necessary.

The test arrives before the meeting

Independence depends on preparation. If compliance first encounters a product or market at the approval meeting, the organization has already designed conflict into the process.

Early involvement creates options. It gives teams time to change the customer journey, strengthen evidence, narrow the launch, add monitoring or test assumptions. Late involvement leaves only two blunt instruments: approve or block.

But even the best partnership cannot remove every hard boundary. Prohibited activity remains prohibited. Unmanageable risk should not be relabeled innovation. A strong relationship with the business matters precisely because it allows the CCO to be direct when the answer is genuinely no.

How to hold the line

Be specific about the risk. Separate regulatory requirement from risk appetite and personal preference. Explain what evidence would change the conclusion. Record the decision and the assumptions behind it. And do not overstate certainty simply to sound authoritative.

When challenged, listen for information—not only opposition. Being independent does not mean being uncorrectable.

There will still be decisions that create disappointment, delay or anger. That discomfort is part of the role. The obligation is to ensure it is the consequence of principled judgment, not poor collaboration.

A CCO should not seek unpopularity. But the organization should know that popularity will never be the control.

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