Rules meet reality inside every legal department, and the general counsel (GC) is usually the one holding both. General counsel compliance management is no longer a back-office function, as it now sits at the centre of how organizations operate, grow, and stay out of trouble. Since the role has changed, the question now is whether the structure around it has kept up.
General counsel compliance management: building before you need it
Cenovus Energy had compliance activity happening across its business. What it did not have was a co-ordinated program, with no chief compliance officer, no centralized view. When Sherry Wendt, Vice-President, Legal & Chief Compliance Officer at Cenovus Energy, came in to change that, she was not starting from zero. She was building a structure around work that was already happening.
“It was really cool because I got to come back to legal… and also stand up a new space that we didn’t have before,” she says. “And in a company this size, this age, it’s not actually that often that you get an opportunity to build a new space in the company.”
Strong general counsel compliance management does not start with a crisis. It starts with the decision to build co-ordination before the absence of it becomes visible.
When the rules don’t line up across borders
After the Husky merger, Cenovus became a global operator almost immediately. That created a compliance challenge with no clean answer: what do you do when the rules in one jurisdiction do not match the rules in another?
Wendt is direct about this. “The complexity of multi-jurisdictional compliance, because the requirements, some of them are very similar, others are different,” she says. “It’s a labyrinth of complexity when you’re operating in multiple jurisdictions.”
For GCs, Canada alone presents layered obligations, such as the following privacy laws for instance:
- federal: Personal Information Protection and Electronic Documents Act (PIPEDA) applies to all private-sector organizations engaged in commercial activity
- provincial statutes: Alberta, British Columbia, and Quebec have their own substantially similar privacy legislation with the PIPEDA
- health information: Ontario, New Brunswick, Nova Scotia, and Newfoundland and Labrador have separate health privacy regimes
- cross-border: personal information crossing provincial or national borders remains subject to PIPEDA, regardless of where the organization is based
Listen to this Canadian Lawyer podcast from CL Talk which discusses litigation and cross-border compliance, among other relevant topics for legal teams:
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Why staying in your legal lane is a liability
Legal expertise alone does not make a GC effective at compliance. “When the only tool you have is a hammer, every problem can start to look like a nail. The more insular you are within the legal team, the more you’re going to fall victim to that,” says Wendt, who was a Lexpert Rising Stars awardee in 2018.
Her advice is to spend time with colleagues outside legal, such as operations and finance, before giving advice, and not after. Understanding how other parts of the business think changes the quality of the guidance legal can offer.
The mandate is growing, but the resources aren’t keeping up
Effective general counsel compliance management increasingly means doing more with the same. According to the 2026 Association of Corporate Counsel (ACC) Chief Legal Officers Survey:
- 35% of CLOs cite budget constraints as their single greatest barrier to success
- 53% say operational efficiency is their top strategic initiative for 2026
- 64% now oversee compliance in addition to their core legal function
- 48% are increasing reliance on outside counsel to absorb regulatory surges
The mandate has expanded, yet the headcount has not. That gap is where general counsel compliance management either holds together, or starts to show cracks.
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