The Revolution in Compliance Training – It is Not Just About Your ABCs
A CCO never feels like he or she has caught up on compliance program requirements. As soon as one new best practice is identified, a CCO blinks for a moment and then there is a new best practice for them to consider.
In the training area, we have seen a rapid change over the last ten years. Years ago, compliance training was a check-the-box exercise where managers and employees were required to take stuffy training programs built around legal concepts to ensure that everyone complied with the law and knew what they were required to do.
In the last few years, we have seen companies’ build sophisticated training programs that leverage technology to maximize the availability and content of training for managers and employees. Companies have built global Learning Management Systems that provide training and professional development services.
The content offered in training programs has multiplied and become much more accessible, interactive and even captured in game-playing format. Foreign-speaking employees are not required to take training programs that they cannot understand because companies are offering training programs in multiple languages.
The most significant transformation, however, may be in recognition of the importance of compliance training to a company’s overall compliance communications program. Compliance training is not just training, but is a much broader communications function revolving around company’s culture, accountability, behavioral norms and leadership expectations.
Companies have taken moribund training opportunities and transformed them into a critical mechanism to communicate internally a company’s set of values and ethical principles. In doing so, they have elevated the technology and the content of training programs to make them more interesting and accessible to managers and employees.
While we can all acknowledge this important trend, the question arises as to where is the training function going in the future? What innovative training ideas will companies develop and what impact will they have?
Compliance training increases awareness – we all understand that. But training is also being extended into new topics and specifically in providing specific guidance on individual compliance functions.
As an example, I have long advocated that important functions, such as accounts payable, should receive specific compliance training so that they understand the important role that they play in identifying potential red flags relating to financial transactions, and how to elevate such concerns when they identify them. In the case of accounts payable staff, they operate as a first line of defense and can effectively provide important compliance program support.
As a result, more companies are engaging accounts payable staff, and other similar functions (e.g. vendor onboarding) and recognizing the important pay offs from training these critical employees.
Given this focused compliance training approach, I expect we will observe more emphasis on specialized training, meaning training that includes not only understanding a legal or code of conduct issue but specific guidance on how each employee can promote effective compliance in his or her day-to-day job.
Compliance training will rapidly move into specialization. This, in turn, will require increased delivery mechanisms, whether in person or web-based training, and could lead to even greater content improvements as training leaders are required to develop new and interesting content for more specialized audiences.