How to Make an Impact as the Chief Compliance Officer of a Digital Assets Business
Stepping into a Chief Compliance Officer (CCO) role at a digital assets firm is a high-impact opportunity. The space is still relatively new, with evolving products and unclear regulatory boundaries. For many businesses in this sector, compliance has either been bolted on as an afterthought, or is being addressed for the first time. As a new CCO, your role is not just to manage risk, but to help shape the operating model of the business in a way that is sustainable and aligned with regulatory expectations.
So what should your focus be in the first week, month, and year?
First Week: Understand the Landscape
Your initial few days should be spent listening, gathering information, and understanding the current state of play.
Start by meeting key people across the business – legal, product, operations, finance, and engineering. Your aim is to understand how the business works, where compliance currently sits, and what’s already in place (formally or informally). You also need to establish which jurisdictions the business is operating in or targeting, and what licences are held or being applied for.
Speak to external legal counsel or licensing consultants early on. Ask for a summary of current regulatory obligations, and understand any engagement history with the regulator. At this stage, you're not designing solutions, you're building a clear picture.
A useful output in the first week is a short 90-day plan setting out your early priorities and how you plan to assess the business.
First Month: Build Structure and Open Dialogue
Once you have a handle on how things operate, start shaping the compliance function.
Create a compliance risk register – what are the key areas of exposure? These may include onboarding and KYC, token listings, cross-border issues, financial crime, or lack of operational controls. Speak to business leads and gather their views on where the pressure points are.
Start a formal dialogue with the regulator. In most cases, it’s better to be transparent from the outset. Explain you’re building a compliance function from the inside out and are keen to ensure it aligns with the regulator’s expectations. Be collaborative, not overly cautious.
Internally, identify individuals who are naturally aligned with compliance, they can help embed the right thinking early on. Begin reviewing existing policies. If they’re outdated or not in use, plan for a new framework.
Quick wins in month one could include getting board approval for a basic compliance framework, running short targeted training sessions, or introducing a simple escalation process for risk or regulatory concerns.
First Year: Embed and Scale
Once the basics are in place, your focus should move to building a proper function that is integrated into the day-to-day running of the business.
One of the biggest challenges in digital assets is that compliance is often seen as a blocker. Shift this perception by showing how good compliance enables faster product development, better client relationships, and smoother regulatory conversations.
Build compliance into the product lifecycle. Make sure compliance has a seat at the table when new features or services are discussed. Consider implementing regtech solutions for transaction monitoring, on-chain analysis, or case management.
Continue engaging with the regulator, ideally on a proactive basis. Provide regular updates on your progress, ask questions early, and don’t wait for inspections to start documenting your work. If you’re part of a newer licensing regime, try to get involved in industry consultations or roundtables – this shows leadership and keeps you close to how the regulator is thinking.
Culturally, your goal in year one is to create a sense of ownership for compliance across the business. Everyone should understand what good looks like and how it applies to their area. Your role is to keep this simple, practical, and commercially relevant.
Key Questions to Ask the Business
To do your job properly, you’ll need clarity on a few things:
What’s on the product roadmap? What new assets, features, or jurisdictions are being considered?
Who owns customer data, and where is it held?
What does the client base look like – retail, institutional, high-risk jurisdictions?
What third-party vendors are being used, and how are they vetted?
What is the board’s true risk appetite?
Answers to these questions will help shape your policy priorities, your regulatory engagement, and the structure of your compliance team.
Working with the Regulator
The relationship with your regulator should be professional and constructive. Don’t wait for formal queries to engage. Reach out early, explain your approach, and ask how they would like to stay informed. Regulators in the digital asset space are still forming their own views – many appreciate firms that are transparent and engaged.
Summarise calls or meetings in writing. Clarify your understanding and next steps. Offer visibility into your internal training or controls. Where appropriate, ask for input – not permission – and keep a record of the advice received.
Bringing Compliance and the Business Together
Ultimately, compliance in a digital assets business is about building trust, with regulators, investors, and customers. It’s not about slowing down the business. If approached correctly, a strong compliance function can act as a differentiator in a competitive market.
Make your function visible, practical, and commercially minded. Create reporting that helps the board understand trends, not just problems. Get in early on business decisions, and suggest alternatives rather than raising blocks.
If you can spend your first year embedding the right structure, engaging constructively with the regulator, and helping the business scale in a compliant way, you’ll be seen not just as the CCO – but as a strategic leader in the company.