On 11 September the Reserve Bank of India published guidelines that called for the appointment of a chief compliance officer at every bank within six months of that date; it has now extended this to nine.

The regulator's aim at the time was to impose 'uniformity' on banks' hiring practices in the compliance market and standardise the quality of candidates and appointees.

In its original circular the Bank wrote: "In respect of banks already having a CCO, they may follow the indicated processes for selection of CCO within a period of six months and are free to reappoint the current incumbent as the CCO if she/he meets all the requirements."

In a recent update to this, to be found in the "frequently asked questions" about the subject on the Bank's website, the Bank writes: "In view of the difficulties expressed by banks, they may follow the indicated processes for selection of CCO in the above circular within a period of nine months from the date of the circular viz. September 11, 2020 and are free to reappoint the current incumbent as the CCO if she/he meets the requirements."

This is a clear reference to the pandemic which has blighted hiring practices all over the world of compliance.

This is a brief reprieve for some older chief compliance officers at banks in India, as the new criteria specify 55 as the top age for these people and a small exodus is expected.