Compliance Training Courses
Do compliance training courses work and do the compliance training courses out there deliver the compliance peace of mind and genuine compliance that employers (and Regulators) are looking for? The evidence would suggest that compliance training courses are but a small part of the solution and employers should not under any circumstances rely on a training centric compliance strategy.
In light of the recent Deutsche Bank fine, it would indicate that in some parts of the market compliance training is certainly not working. In fact if you read the FCA comments it would suggest that Deutsche Bank might not be alone in having poor controls around Regulated activities and processes. Whilst it is perhaps unfair to single out Deutsche Bank, this might serve as a kick in the pants for numerous other organisations.
According to the FCA, Deutsche Bank failed “to properly oversee the formation of new customer relationships and the booking of global business in the U.K.” and ordered it to pay the £163 million charge ($203.83 million) – the largest penalty ever applied by the British regulator.
Whilst Deutsche Bank’s Karl von Rohr, chief administrative officer was keen to point out that considerable improvements have been made and continue to be made, the bank and many other players in the market still do not embrace best practice in this area. A lack of compliance training courses perhaps?
So – Compliance Training Courses?
Training is only as good as the extent to which an individual/employee learns the material. You can attend endless compliance training courses and unless you learn the content you are arguably as ignorant as you were before you attended the training. Most firms get this but, when it comes to establishing or proving learning has occurred, they fall down.
Best practice would suggest that employees engage in continual assessment and that this assessment takes the form of a relevant and hard to ‘cheat’ process. Continual in this context meaning assessment occurs every day.
If Deutsche Bank could have proven at the click of a mouse that every relevant employee was assessed randomly every single day and that each individual had achieved and continued to achieve the required standard or were automatically receiving re-training, would FCA have been quite so punitive? In such circumstances would Deutsche Bank not have been forgiven for appealing to FCA and asking “what more could we possibly do to ensure that each and every one of our staff had been trained and genuinely learned and retained the material relating to AML? Demonstrable compliance training courses that are backed up with a mechanism that ensures training becomes learning, and that this learning is retained.
I’m not suggesting that adopting a continual assessment strategy would have entirely absolved Duetsche Bank, but I would posit that the ability to prove absolutely individual employee capability on a daily basis would have mitigated the punishment. In this instance, compliance training courses made to deliver the desired outcomes of knowledgeable and capable and compliant employees?
What are the compliance training courses options?
So what are the choices? Ignore the elephant in the room, or find a genuinely effective solution to the issue that Deutsche Bank and thousands of other firms are investing in the wrong place and thereby exposing their firms to unnecessary risk. Simply investing in compliance training courses and auditing services hoping to ‘catch’ the ones that didn’t learn it via some random on-going dip-checking audit isn’t overly supportive on the employee engagement spectrum! Better surely to collaborate with the workforce, dip-check in a structured and random way every day and support the learning of the content so employees become genuinely competent with the material. Compliance training courses or intelligent learning and knowledge retention?
Nelly? Because Elephants Don’t Forget
Clever Nelly from Elephants don’t forget is an Artificially Intelligent, cloud hosted application that sits on email, a smart phone or any tablet, and interacts with your individual employees validating current knowledge and compliancy standards set by the regulator. Nelly does not deliver a compliance training courses per se, and is largely training agnostic: she doesn’t mind who you use or what you train your employees so long as it is accurate and relevant. Nelly works with your employees after they have received training post compliance training courses!
Best of all Nelly runs less than 2 minutes a day in maintenance mode which means even the busiest time poor employee has time to engage and genuinely learn. If you read the Deutsche Bank material and have concerns that your reliance on compliance training courses might be misplaced, then perhaps you should consider how you could augment your current activities and materially reduce your risk by hiring an elephant to your team.
Compliance Training Courses – Don’t just take our word for it – Clients