Director of Compliance

Job Title: Director of Compliance Department: Office of the General Counsel  Location: Sierra Club office, and/or remote. This position requires an ability to travel.  Reports To: General Counsel - General Administration  Supervises: Compliance staff  Context: At the Sierra Club, we believe in the power of interdependence. Together, we remain committed to the fight for a healthy climate built on a foundation of environmental, racial, economic, and gender justice – a future where all people benefit from a healthy, thriving planet and a direct connection to nature. As the climate crisis and deeply entrenched systemic racism all fuel injustice, we will continue to fight for a bold, transformational agenda that recognizes the interconnectedness between our planet, our humanity, and our future. By recognizing that our destinies are tied, we continue to name that all things are fundamentally connected, and the overlap between ecology, race, gender, and representative government will move to either advance our collective humanity or to oppress it. Sierra Club has close to 700 staff across the country and a network of 64 local chapters that are led and fueled by thousands of volunteers. We are also proud to be a unionized employer, with three labor unions representing more than half of our employees. Scope: The Director of Compliance is a Juris Doctor admitted to practice and in good standing with the State bar of relevant jurisdiction where located and practicing law who is responsible for protecting Sierra Club’s integrity, reputation, and viability, supporting its staff and board in carrying out the mission within a secure legal framework. The Director of Compliance is responsible for all aspects of Sierra Club’s program compliance operations, including compliance review, approval, enforcement, and training functions for all Sierra Club programs--501(c)(3), 501(c)(4), Voter Education (527), and various political action committee (PAC) funds. This role manages overall risk management related to program compliance issues, including decision-making authority on organizational-level approvals for activities and programs. This position establishes and enforces relevant policies, procedures, and controls. The Director of Compliance develops new operations and processes to match new regulations or program goals. This role coordinates closely with The Sierra Club Foundation and relevant experts regarding compliance issues and the uses of restricted funds. The Director of Compliance stays abreast of applicable laws and regulations and ensures that Sierra Club maintains compliance at all times. This role provides expert legal and ethical advice to senior leaders and the general counsel to assist in vital risk mitigation efforts and to safeguard organizational effectiveness.   Job activities include but are not limited to:

C3/C4 Compliance and Analysis

Monitor and advise on compliance with federal, state, and local laws governing nonprofit organizations, including charitable solicitation, tax exemption, employment, privacy, and lobbying.​

Draft, review, and revise contracts, grant agreements, and related organizational policies.

Conduct compliance audits and risk assessments; recommend and oversee corrective actions as necessary.​

Maintain the organization’s tax-exempt status by collaborating to ensure timely IRS filings and compliance with IRS rules and regulations.​

Make funding determinations for 501(c) activities based on IRS regulations and internal Sierra Club and fiscal sponsorship requirements. 

PAC and Election Reporting 

Act as point of contact for inquiries from the FEC, state agencies, regulatory bodies, and external counsel; manage responses to audits, investigations, and enforcement actions.

Collaborate with the compliance team to provide guidance on advocacy, advertising, issue campaigns, and independent expenditures, including proper disclaimers, reporting, and compliance with federal, state, and local rules.​ 

Draft and review PAC governance documents, contribution solicitations, political communications, and related contracts and agreements.​

Oversee all legal and compliance matters associated with PAC registration, administration, contributions, expenditures, and reporting at the federal, state, and local levels.​

Review all required reports for the Federal Election Commission (FEC), LDA, IRS, and relevant state agencies, ensuring thorough and timely disclosure of PAC receipts, disbursements, and activities.​This position will not be tasked with preparing or filing federal campaign finance or lobbying reports, but will be required to review these reports.

Develop Sierra Club chapter political compliance support processes.

Monitor legislative, regulatory, and enforcement developments related to campaign finance, election law, lobbying, and ethics and take action as needed.​

General

Develop and enforce written policies and procedures for program compliance rules in accordance with: IRS code, FEC regulations, State Election agencies, internal Sierra Club policies, The Sierra Club Foundation policies, industry practices, and donor intent. Written policies and procedures include operational and financial guidelines, processes, and controls; maintains required documentation; and establishes and produces management reports.

Oversee the program compliance training function, including the development, preparation, and distribution of compliance materials to board, staff, and volunteers on relevant legal and compliance topics.​

Provide guidance to board members, senior management, and staff regarding corporate governance, fiduciary responsibilities, and ethical conduct.​

Stay current with trends and changes in nonprofit law and regulations; proactively communicate potential impacts.​

Liaise with external counsel and regulatory agencies as needed.​

Ensure external regulatory and policy changes are tracked. Acts as the principal liaison with outside counsel to prepare materials that interpret regulatory and policy changes and informs Sierra Club senior staff of impacts to existing or contemplated programs. Works closely with Senior Staff to create new programs to meet changing regulations.  Monitors and enforces organization-wide adherence to all program compliance guidelines.

Hire, train, and manage Compliance staff. Review staff work and provide feedback, coaching, and support; complete annual performance evaluations and goal setting. 

Perform miscellaneous duties as requested or assigned.

The successful candidate must demonstrate the following skills, experience and competencies:

JD degree from an accredited law school; active and valid law license.​

Minimum of 3+ years’ relevant legal and/or regulatory compliance experience working with a 501(c) organization or similar in-house (including non-profit or exempt organization) experience.

Deep knowledge of nonprofit law, organizational compliance, and risk management.​

Strong knowledge of IRS regulations and tax laws regarding 501(c)(3) and 501(c)(4) funds administration and generally accepted accounting principles. 

Demonstrated experience in contract review, policy development, and regulatory filings.​

Ability to translate complex legal issues into practical guidance for staff and leadership.

Demonstrated skill and effectiveness in preparing training and instructional materials and in delivering training programs.

Strong verbal and written communication skills; excellent attention to detail.​

Commitment to the mission and values of the nonprofit sector.​

Committed to evolution. You are committed to continuously deepening and evolving your own understanding of systems of oppression through study, openness, and humility. And you easily recognize your own relationship to privilege and power, examining and shifting your behaviors as appropriate.

Uplifting and additive. You see mistakes as opportunities for growth; problems as catalysts for solutions, and inspire others along the journey. You carry a constructive approach, can-do attitude, a sense of humor, and authentic kindness wherever you go.

The strongest candidates will also demonstrate the following skills, experience and competencies:

Experience with grant funding, lobbying compliance, and charitable solicitation regulations.​

Strong knowledge of FEC regulations and reporting requirements; experience in preparing campaign finance reports or similar. 

Familiarity with multi-state compliance issues and employment law.

Collaborative approach, ability to work independently, and commitment to diversity.​

Experience with board training and governance.​

Understanding of fiscal sponsorship model c structure. 

Experience in a managerial role that includes staff management, establishing policy, and policy enforcement.  

Familiarity with engaging with volunteers on various matters.