One issue not often considered by compliance professionals around compliance training is that of compliance training governance. Yet a multinational organization subject to the FCPA faces many legal and regulatory risks and often many of those risks are “owned” by organizations that are outside of the compliance function. How can your organization, create a comprehensive compliance training program that covers its complete risk profile?
In the age of Coronavirus, any multinational organization will have a broad risk portfolio which are typically owned across the organization. Consider compliance risk, fraud risk, reputational risk, financial accounting risk and discrimination risk. These are but a small sample of risk many of the risks will not be “owned” by the corporate compliance function. This presents a real challenge when you are trying to create a comprehensive compliance training program covering all of legal, regulatory, compliance and reputational risks faced by a company. Shawn Rogers suggests that one approach “is to establish a corporate Compliance Training Governance Committee that looks at the company’s overall risk profile and builds a cross-functional and comprehensive multi-year training plan that effectively addresses all of the risks in a company’s risk portfolio.”
A Compliance Training Governance Committee will allow your organization to effectively establish a multi-year training plan, help in the vendor selection and engage in course creation. Rogers said that “One of the biggest benefits has been the predictability that it brings to the compliance training program. Every stakeholder from a risk-owning organization knows exactly when their function will have their course deployed over the three-year calendar. They can plan resources, they have a long lead-time to develop the courses and during their off-years they can do communications campaigns and events to keep their risk top-of-mind.”
Three key takeaways:
- Why your organization should create a Compliance Training Governance Committee.
- Who should be on the Compliance Training Governance Committee?
- How should the Compliance Training Governance Committee work going forward?