The DOJ, in its recently updated Evaluation Of Corporate Compliance Programs document, suggests that a “hallmark of a well-designed compliance program is appropriately tailored training and communication”. In this part of the discussion we asked our experts to zero in on the practical challenges of doing this right.

There are, after all, so many rules for employees to be aware of that the engagement with training content can be low and does not always deliver good results for the business.

Wright kicked off by saying that she “does not believe that HR should be responsible for training at all.” While they can “hold the budget and facilitate the execution” the content itself “must come from specialists within the organization”. In Wright’s experience “if you deviate from this you end up with real problems straight away” and she suggests that “actually compliance officers should be able to explain anything complicated in simple enough terms to those who have to understand it” because this is, and should be, “part of their expertise.”

“Even with good content, getting people to engage with rules is difficult.”

Emily Wright

Her recommendation to organizations is to try to “leverage their experts” but she does not believe that this is going to solve the issues with engagement because “even with good content, getting people to engage with rules is difficult”. Mason wholeheartedly agreed suggesting that even good, highly motivated staff consider mandatory training dull and unengaging.

According to both Mason and Wright online training is overused.

When you join a bank you may sometimes need to complete over 45 hours of mostly online training. According to Mason just looking at the list of training requirements can “make your eyes sting”. And he suggests that while it is a good way to read stuff, to test whether it has been read and provide employees with content and context it is “not a great way of generating engagement. And you do need people to engage because the firm remaining compliant depends on it”.

He does not believe that online training works, primarily because “it is either common sense or so disconnected from what you are doing that you end up simply memorizing unhelpful snippets of information.” Also, there are no consequences to failing.

“Bringing people to a common level of understanding of even the fundamentals can be incredibly challenging.”

Rob Mason

Staff “go through the process, sometimes multiple times, without improving or enhancing their knowledge.” And another issue is the size of the financial institutions in question, particularly the banks. An average bank has about 60,000 employees. “It is very hard to deploy training that is effective across such a big range of employees because if you think about the variety of roles, coupled with the diversity of experience, bringing people to a common level of understanding of even the fundamentals can be incredibly challenging,” Mason reckons.

Wright believes that tailoring the training to make it relevant to the job that people do is key to engagement and good results. “You need to give employees the contextual alignment for them to be able to make good judgement when something occurs that needs to be challenged or flagged” and a “one way transmission does not permit you to test the theory or prepare people for this”.

Ideally what you need is practice, whether this takes the form of “role playing, discussion or scenario based workshops.” What you effectively need is “two way communication” so that the nuance and the real-life challenges that employees face can be a part of the training.

But Wright acknowledges that scaling in-person training can be difficult and expensive. And so both our experts believe that this represents a big opportunity for AI.

They envision an AI agent “available to answer questions in real time at your desk.” And Wright says that this would mean “you don’t have to ring somebody, you don’t have to hire thousands, but instead of replacing advisory and compliance staff you augment what they do with technology.”

The big differentiator between employing AI in this context versus the sort of static training and asset building that teams are currently forced to do is the feedback loop, which means that AI can adapt and “redact the scenarios” and so “really test your knowledge” of a specialist subject and ensure that you can “demonstrate that you understand.”

Other articles in this series

• Compliance and HR in the second line of defense – a new paradigm
• Ensuring senior management follows the rules
• FCA non-financial misconduct survey
• Challenges and opportunities in surveillance today