Head of compliance leaves: filling the role on an interim basis

Short answer: When the head of compliance leaves, the compliance function must keep working without a gap. German banks must always have a designated compliance officer under MaRisk AT 4.4.2, and Swiss banks need an effective compliance function under FINMA Circular 2017/1. An interim head of compliance runs the function until the successor is in post. Responsibility stays with senior management.

This guide is for executive boards, boards of directors and HR leads in Switzerland and Germany whose head of compliance resigns, falls ill or moves internally. It covers what to settle in the first ten days, which supervisory rules apply, and how to set up the mandate and handover for an interim head of compliance.

What to settle in the first ten days

The first ten days are about securing responsibilities, capturing deadlines and informing the right bodies. This sequence works well:

1. Appoint cover: Record in writing who leads the compliance function from now on and who may sign off. If the head of compliance is also the money laundering reporting officer (MLRO), in Germany the appointed deputy takes over (section 7(1) German Anti-Money Laundering Act, GwG).
2. Inform the boards: German institutions must inform the supervisory board in good time and in advance, with reasons, when the compliance officer position changes (MaRisk AT 4.4.2 para. 8). In Switzerland the compliance function has direct access to the board of directors, so the board should hear early.
3. Check notifications: If the MLRO changes with the head of compliance, Germany requires advance notice of the appointment and removal to the supervisory authority (section 7(4) GwG). In Switzerland the money laundering unit (Geldwäschereifachstelle) must be designated again if that person held the role (art. 24 FINMA Anti-Money Laundering Ordinance, AMLO-FINMA).
4. Capture deadlines: List open reports, audit findings, training, board papers and requests from the regulator and internal audit, each with a date and an owner.
5. Secure access: Files, case systems, mailboxes and powers of attorney must not stay tied to someone who is leaving.
6. Decide: Internal cover, an interim head of compliance, or both? Selected profiles are usually available within 48 hours; the start date is agreed between the company and Alpinum.

The general steps after a resignation in the legal team are set out in our action plan when a legal counsel resigns. Compliance adds the supervisory points above.

Supervisory requirements for the compliance lead in Switzerland and Germany

Banks and other supervised institutions in both countries need a compliance function that works at all times, so a gap at the top is an organisational risk. The table summarises the key rules.

Outside financial services there is usually no statutory duty to have a head of compliance. The work remains, though: whistleblowing channels, sanctions screening, data protection and internal investigations carry on. German investment firms should also check the rules under the Securities Trading Act (WpHG) and BaFin's MaComp.

Interim head of compliance: profile and mandate

An interim head of compliance is an experienced compliance professional who leads the function and the team for a defined period. Most companies look for senior profiles with leadership experience in the same sector, because the regulator, internal audit and the external auditor expect a knowledgeable counterpart.

• Expertise: working knowledge of the relevant rules (FINMA circulars, MaRisk, GwG), compliance risk assessment and reporting to management and the board.
• Leadership: able to lead an existing team without a long ramp-up and to set priorities quickly.
• Independence: no conflicts of interest with the business lines being monitored.
• Workload: part-time or full-time, between 20 and 100%, depending on the size of the function and the state of the team.

A one-page mandate sets out tasks, authority, reporting line, workload, expected duration and handover. Under staff leasing the company directs the work and the professional is integrated into the organisation; under freelancing the professional works independently within the agreed mandate. For a lead role with authority over the team, staff leasing is often the natural choice. For the wider role profile, see our guide to the interim compliance officer.

Handover, reporting and authority

An interim head of compliance is only effective with the same authority and information rights as the previous lead. MaRisk AT 4.4.2 para. 6 requires sufficient authority and unrestricted access to all necessary information; FINMA Circular 2017/1 gives independent control functions unrestricted rights to information, access and inspection.

• Authority: set out sign-off rights, signing authority, escalation rights and committee membership in writing.
• Reporting: a first status report to management after two to four weeks; keep the annual report and the activity plan on schedule.
• Handover from the predecessor: where possible, a handover meeting with a list of open cases, deadlines and contacts at the regulator and the external auditor.
• Handover to the successor: plan an overlap and keep documentation current throughout.

Recruiting the successor in parallel

The interim head of compliance bridges the gap while the permanent search runs in parallel. Keep the two processes apart: the interim lead runs the function, management runs the search. That keeps the interim lead independent, and the successor inherits an orderly function. A move into the team (temp-to-perm) is possible; the terms are agreed in advance. How such an assignment typically runs is described in our typical assignment: interim head of compliance during a vacancy.

Limits and risks

• Responsibility stays in-house: management remains responsible for compliance with the rules; an interim lead does not change that.
• No legal advice from Alpinum: Alpinum provides professionals. Whether a regulator must be notified is for the institution to decide, with its auditor or law firm where needed.
• Outsourcing is not the same as reinforcement: in Germany, fully outsourcing the compliance function is allowed only in narrow cases (MaRisk AT 9 para. 5). An integrated interim lead is different, but should be documented properly.
• Interim period running long: if the successor is still open, extend the mandate deliberately and review workload and priorities.

Frequently asked questions about a head of compliance vacancy

Can the head of compliance role be filled on an interim basis?

Yes. Neither MaRisk nor FINMA Circular 2017/1 requires the lead to be a permanent employee. What matters is that the function works effectively and independently, with sufficient authority. An interim lead under staff leasing is integrated into the organisation and takes professional direction from the company. Document the mandate, authority and reporting line.

Does the regulator have to be told?

It depends on the role. In Germany the supervisory board must be informed in advance when the compliance officer changes (MaRisk AT 4.4.2 para. 8). If the MLRO also changes, the supervisory authority must be notified in advance (section 7(4) GwG). In Switzerland, check with your external auditor whether the person's position triggers a notification to FINMA.

How quickly is an interim head of compliance available?

Selected profiles are usually available within 48 hours; the start date is agreed between the company and Alpinum. Typically two to four profiles are put forward per search, and the company runs the interviews itself. How quickly the assignment starts depends mainly on the candidate's notice period and on the internal decision.

How long does an interim compliance mandate last?

It lasts until the successor has been onboarded. The duration depends on the permanent search and the successor's notice period. Plan a review after two to four weeks and fixed checkpoints after that. This lets you adjust workload, focus and duration without putting the function at risk.

Can we hire the interim head of compliance permanently?

Yes. A move into the team (temp-to-perm) is possible; the terms are agreed in advance. It makes sense when the interim lead has proved themselves and fits the role. Even so, keep the interim mandate and the recruitment process separate so that the function stays independent during the transition.

Next step

Alpinum Solutions is the leading provider of interim legal & compliance in the DACH region and provides heads of compliance and compliance officers through staff leasing and freelancing. Tell us about the function, workload and timing, and we will propose suitable profiles.

• Interim compliance: filling compliance leadership and compliance officer roles
• Typical assignment: interim head of compliance during a vacancy
• Staffing needs and planning: all guides
• Personal liability in a compliance role: what to settle for interim appointments
• Discuss your needs

Last updated: 11 November 2026.