Underpaid in Risk, Audit or Controls? How to Benchmark Your Pay Properly

Most people who wonder whether they're underpaid answer the question with a salary website and a feeling. In risk, audit and controls, both give you the wrong answer.

The website averages your seat with thousands of jobs that aren't yours. The feeling usually comes from one data point: a peer's offer, a recruiter's number, a new hire you suspect earns more than you. Neither tells you what your specific scope is worth at the kind of firm you could realistically move to.

Here's how to benchmark properly, using public data that's better than most people realize, and how to tell being underpaid apart from simply feeling it.

Why National Salary Data Says You're Fine

Start with the most reliable public source, the Bureau of Labor Statistics' Occupational Employment and Wage Statistics survey. For May 2025, the national figures for the closest occupations look like this (BLS OEWS):

Financial risk specialists: median $117,330. The 75th percentile is $158,250 and the 90th is $196,110.

Compliance officers: median $80,730, with the 90th percentile at $133,720.

Accountants and auditors: median $83,680.

Financial managers, a category BLS says includes risk managers: median $166,570.

If you're a Manager earning $150,000, these numbers say you're doing well. You're above the 90th percentile for compliance officers and close to the 75th for risk specialists. That's exactly the problem. These categories mix every industry, every city and every level from analyst up. A healthcare compliance analyst and a compliance Manager at a trading firm sit in the same bucket. National percentiles tell you where you sit among everyone. They don't tell you what your seat pays.

Same Occupation, Different Firm

The same BLS survey shows how much the answer moves when you narrow it. Median pay for financial risk specialists in May 2025:

Credit intermediation (banks and other lenders): $112,060.
Securities and other financial investment firms: $133,070.
New York metro area: $139,670.

For compliance officers, the median is $83,650 in credit intermediation and $100,160 in securities and investment firms. In the New York metro area it's $101,050.

That's roughly a $16,500 to $21,000 difference in the median for the same occupation, depending on the type of firm, before any bonus. It's also the most common reason people are underpaid without knowing it. They benchmark against their own sector, where everyone is paid similarly, and never check what the same work pays in the one next to it.

The line of defense moves the number as well. Pay is funded and set differently in the first, second and third lines, so a controls Manager in the business and a risk Manager in the second line can be paid very differently for overlapping skills.

Build A Comparison Set From Real Postings

The best benchmarking source didn't exist a few years ago. Several states now require pay ranges in job postings, which means real employers publish what they expect to pay for real seats:

California: employers with 15 or more employees, since January 1, 2023 (California Labor Commissioner).
New York: employers with four or more employees, since September 17, 2023, including promotions and transfers (NY Department of Labor).
New Jersey: covered employers since June 1, 2025 (Ogletree).
Massachusetts: employers with 25 or more employees in the state, since October 29, 2025 (Mass.gov).

Postings from these states are useful benchmarks even if you work somewhere else. Just adjust for location, because the same seat pays differently in different metros.

Build the comparison on scope, not title. Titles in risk and audit are unreliable: a VP at one bank does the work of a Director at another. Match on the things that actually set pay:

Team: how many people you lead, and whether they're analysts or managers.
Regulatory exposure: whether you face examiners directly or support someone who does.
Reporting line: how far you are from the committee or the board.
Firm type: bank, broker-dealer, asset manager, insurer, fintech.

A small set of postings that genuinely match your scope beats a large set that only matches your title.

Read The Posted Range Like A Hiring Manager Does

It's usually base pay only. California's Labor Commissioner says compensation beyond salary or hourly wage, such as bonus, doesn't have to be posted. In financial services, where bonus can be a meaningful part of the package, compare base to base and ask about bonus separately.

The range is what they expect to pay. Laws define it in terms of what the employer reasonably expects or believes to be accurate. Most offers land somewhere inside the range, and the top is usually reserved for candidates who exceed the spec.

Wide ranges hide levels. A range that runs from $120,000 to $210,000 often means the firm will hire at different levels depending on the candidate. Read the requirements to work out which end you'd realistically land at.

Ask For Your Own Band

Market data tells you what the seat pays elsewhere. Your band tells you where you sit where you are, and that's often where being underpaid actually shows up.

In some states you can simply ask. Massachusetts gives current employees the right to the pay range for their own position on request. California also requires employers to give current employees the pay scale for their position when they ask. Even where there's no legal right, HR or your manager will often share the band if you ask directly.

What to look for: if you've been in the seat for years, your scope has grown, and you still sit in the bottom part of the band, that's a pay problem your employer can see and has chosen not to fix. That's a different conversation from "I think the market pays more."

What Staying Actually Costs

You'll often hear that changing jobs is the only way to get a real raise. The data is more specific than that.

The Federal Reserve Bank of Atlanta's Wage Growth Tracker, built on the Current Population Survey, compares wage growth for people who changed jobs with people who stayed. On a 12-month moving average, median wage growth in August 2026 was 4.4% for job switchers and 3.6% for job stayers. In December 2022, near the peak of the post-pandemic hiring market, it was 7.7% versus 5.6%.

So on the median, switching pays a bit more, and the premium grows when hiring is hot. But a 0.8 percentage point difference on a $150,000 salary is about $1,200 a year. That isn't what people mean when they say they're underpaid.

The big gaps come from structure, not from the act of moving: changing level, changing firm type, or changing line of defense. There's also evidence that firms pay a premium for outsiders. Research by Wharton's Matthew Bidwell at a US investment bank found external hires were paid about 18% to 20% more than people promoted internally into similar jobs. We covered what that means if you've just been passed over for a Director seat.

Three Signs You're Actually Underpaid

1. Comparable postings sit clearly above you. Not one outlier, but most of a comparison set built on scope. If the midpoint of real ranges for your scope is above your base, that's evidence.

2. Your scope grew and your band didn't. You took on a team, a new regulatory area or a remediation program, and your title and band stayed the same. This is the most common version at Manager level.

3. The firm is paying more to hire people into seats like yours. If postings for your own team's roles show ranges above your pay, the firm has already told you the market rate.

If none of the three applies, you may be paid fairly for the seat you're in, and the real question is whether you should be in a bigger one.

What To Do With The Answer

If the gap is inside your band, make the internal case with evidence: the comparison set, your expanded scope, and a specific number. The mechanics of that conversation are in our piece on what actually moves the number in a salary negotiation. The principles apply well beyond AML.

If the gap is the seat itself, no raise will close it. The fix is a different level, a different firm type or a different line of defense, and that's a positioning problem, not a negotiation. Panels hire at the level your record reads as, so the work is making it read as the level you want. That's a big part of what an interview panel is actually scoring.

If you move, negotiate the whole package. Title, scope, base and bonus together. A higher base on a smaller scope can cost you the next promotion.

A salary website ranks you against everyone. A scope-matched comparison tells you what your seat is worth.

Questions People Actually Ask

How do I know if I'm underpaid in risk or compliance?

Build a comparison set of real job postings that match your scope, not just your title, using states that require pay ranges. If most of them sit clearly above your base, or you sit low in your own band after your scope has grown, you're likely underpaid.

What is the median salary for a financial risk specialist?

According to the BLS, the national median was $117,330 in May 2025. It varies by firm type and location: $112,060 in credit intermediation, $133,070 in securities and investment firms, and $139,670 in the New York metro area.

Do posted salary ranges include bonus?

Usually not. California's Labor Commissioner says pay beyond salary or hourly wage, such as bonus, doesn't have to be posted. In financial services, compare base to base and ask about bonus separately.

Does changing jobs increase pay more than staying?

On the median, modestly. The Atlanta Fed Wage Growth Tracker showed 4.4% wage growth for job switchers versus 3.6% for stayers in August 2026 on a 12-month average. Larger gains usually come from changing level or firm type.

Can I ask my employer for the pay range of my current job?

In some states, yes. Massachusetts and California give current employees the right to the pay range for their own position on request. Elsewhere, many employers will share it if you ask directly.