The government has stated that a well-designed compliance program includes “appropriately tailored training and communications.”  Compliance policies cannot work unless effectively communicated throughout a company. Communications and training programs ensure that directors, officers and employees are aware of and follow compliance policies and procedures.  Indeed, the Justice Department’s recent Evaluation of Compliance Program Guidance noted that integration of a company’s policies and procedures should include periodic training...

We all know the scene but choose to ignore it – a senior employee or manager is taking an online training course and is talking on the phone, writing emails and basically ignoring the training session. Why? Because it has no importance to the employee’s job. It is irrelevant but something he or she has to complete. A check the box task if ever there...

The next time we read about a train wreck of corporate malfeasance – be it in the anti-corruption, money laundering, financial reporting or any other space you can think of – please do not shrug your shoulders and shake your head from side to side. Instead, let’s consider how the board and senior management handled the specific matter, why they failed to address any concerns...