The world of legal compliance is a pressured one, with few positions carrying the weight of personal responsibility quite like that of the compliance officer for finance and administration (COFA).
As a professional body dedicated to supporting COFAs across the legal sector, the ILFM regularly witnesses the challenges and pressures faced by those who step into this crucial role.
The reality behind the title
The COFA role comes with significant personal liability attached to what might initially appear as simply another title added to an already busy professional’s portfolio.
While many law firms have robust finance departments handling day-to-day compliance matters, it’s important to recognise a fundamental truth: regardless of who performs the actual compliance work, the COFA has the primary responsibility of ensuring the firm, and its managers and employees comply with the SRA accounts rules.
The firm is also responsible for ensuring that it has systems and controls in place to enable the firm, its managers and employees to comply with the rules’ requirements.
We frequently come across situations where COFAs are removed from the operational aspects of compliance yet remain personally accountable where they fail to meet their responsibilities. For many, this represents an invisible burden – your name stands on the firm’s documentation as the responsible individual, while the practical implementation of compliance measures happens elsewhere in the organisation.
The expanding scope of COFA responsibilities
The role has evolved significantly since its inception. Today’s COFAs must navigate an increasingly complex regulatory landscape that includes:
- Ensuring compliance with the SRA accounts rules;
- Overseeing financial stability and risk management;
- Monitoring and reporting serious breaches;
- Implementing robust financial controls and systems; and
- Contributing to the firm’s overall compliance culture.
What makes these responsibilities particularly challenging is their intersection with other compliance areas. Financial compliance doesn’t exist in isolation – it frequently overlaps with anti-money laundering requirements, data protection regulations, and broader firm governance, creating a multi-dimensional compliance environment that COFAs must understand and navigate, not to mention the fact that in smaller firms COFAs are often fee-earners too!
Personal liability: The sharp end of compliance
The personal liability aspect of the COFA role cannot be overstated. Recent regulatory actions have demonstrated the Solicitors Regulation Authority’s willingness to hold individual compliance officers accountable for systemic failures.
When things go wrong, it’s often the COFA’s name that appears in regulatory findings, disciplinary proceedings and sometimes, unfortunately, in industry publications.
This exposure creates not just professional risk but personal stress. Many COFAs report experiencing anxiety about potential compliance failures that might be occurring outside their direct control or knowledge.
The burden of knowing that your professional reputation stands on the line for processes you may not directly oversee is considerable.
The resource challenge
In our conversations with members, a common theme has emerged: a disconnect between the level of responsibility placed on COFAs and the resources available to them.
Many COFAs, especially in smaller firms, report that they are not given dedicated time to focus on compliance duties. They often lack the authority needed to implement necessary changes, face challenges in securing budget for compliance systems and training, and encounter resistance when trying to introduce more robust processes.
This gap in support is particularly concerning given the expectation that COFAs remain up-to-date with regulatory developments and ensure their firms respond appropriately – all while continuing to manage their core responsibilities.
Building effective relationships with finance teams
Given that much of the practical compliance work often falls to finance teams, successful COFAs need to establish strong working relationships with these departments.
This isn’t just about delegation – it’s about creating channels of communication that ensure the COFA remains informed and can provide appropriate oversight.
This might include regular structured reporting from finance teams to the COFA, clearly set-out documentation of compliance procedures and responsibilities, training held jointly and agreed escalation procedures for any potential compliance issues.
These collaborative approaches help bridge the gap between responsibility and implementation, providing COFAs with greater visibility into the compliance activities being conducted under their ultimate supervision.
Finding support in the compliance community
Perhaps the most important message we can share with COFAs is this: you are not alone. The challenges you face are shared by peers across the profession, and there is strength in community.
Whether through formal membership organisations like the ILFM, professional networks, or mentoring relationships, connecting with fellow compliance professionals provides both practical support and emotional reassurance.
When regulatory scrutiny intensifies or compliance challenges arise, having a trusted community to turn to for guidance, perspective, and sometimes simply understanding, can make all the difference.
This article was first published on Legal Futures here
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