What should be your organization’s compliance training frequency? How does the amount of training can positively or negatively impact an overall training strategy? Unfortunately, these questions were not answered by the 2020 Update or the 2020 FCPA Resource Guide. Still every company should have a “well-designed compliance program is appropriately tailored training and communications.”

Often compliance professionals think that compliance training needs to be conducted very frequently, even if it means repeating the same training courses every year. However, Shawn Rogers analogizes compliance training to an automobile’s windshield wiper system in a discussion of how frequently compliance training should be administered. He went on to explain that “it would not make any sense to run your wipers constantly, even when it is not raining. First, it would be extremely annoying to the passengers. And second, eventually it would wear out both the wiper blades and the wiper motor. It would simply be nonsensical.” Requiring overly repetitive training is like running your windshield wipers in clear weather. The learners are going to be annoyed, the training will be viewed as a waste of time and energy and finally your employees will not take training as seriously when it is really needed to address a specific situation as the compliance training will be viewed literally and figuratively as a “check-the-box” exercise.

While new employees should be required to take more detailed courses during their first year so that they are exposed to the key risks in detail, after that, full-length courses can be staggered in a three-year interval so you can keep the courses updated and to avoid over-training. In the interim, you can move towards a less frequent repetition of lengthy training courses and more frequent refresher or reminder training modules that keep the risk top-of-mind without assuming that lengthy courses need to be repeated every year. Once again this fits the 2020 Update prescription that “companies have invested in shorter, more targeted training sessions to enable employees to timely identify and raise issues to appropriate compliance, internal audit, or other risk management functions.” Rogers concluded “It is a very common sense and defensible approach to compliance training.”

 Three key takeaways:

  1. Have a well-reasoned approach to training frequency.
  2. Lengthier more full-bodied training can be given once every three years or so.
  3. Shorter more frequent compliance refreshers or reminders can be used to keep the risk top-of-mind.