One of the key goals of any compliance program is to train employees in awareness and understanding of the FCPA; your specific company compliance program; and to create and foster a culture of compliance. While it seems axiomatic that compliance training is a mainstay of any best practices compliance program, the conversation around training has evolved over the years.

The importance of determining effectiveness of your compliance program has been enshrined by the DOJ. The 2020 Update confirmed that the DOJ wants to see evidence of the effectiveness of your compliance program. This is something that many CCOs and compliance professionals still struggle to determine. Both the simple guidelines suggested herein, the more robust assessment and results provide you with a start to fulfill the precepts set out by the DOJ, as you will eventually need to demonstrate the effectiveness of your compliance training going forward.

Three key takeaways:

  1. How and why have you tailored your compliance training?
  2. The DOJ has mandated demonstrating the effectiveness of compliance training
  3. How is your training presented: both in languages and media?