The reason most compliance training does not work is that it's not training at all.
It's education. And if you try to deliver compliance education when you should be doing training, you'll end up with massively unhappy employees who still don't know what to do.
Here's a quick rundown of the difference:
Education is broad. It's for people who need a flexible understanding of the material, because it relates to the core of what they do. So it's usually gonna be focused on things like concepts and frameworks to help people get this really broad, flexible understanding that they can apply in a variety of contexts.
Training, by comparison, is far more targeted and focuses on specific skills and tasks. It's inherently going to feel more practical than education.
Training is really for people who don't need the entire forest. They just need to know how to deal with like the one tree that impacts what they do. That is they don't need to have this broad understanding of the material, because the material isn't their job. They just need to understand the limited part that's relevant to them.
Let me illustrate. I am recording this around tax season, and if you're like me you pay someone else to do your taxes Because, like, you're not a tax expert, And, like, it stresses you the fudge out. So you want someone else to tell you what to do. It's my tax guy that needs education, because that's his core job duty, right?
So like he needs to be the one that has this really broad, flexible understanding so he can apply to all these different circumstances. On the other hand I just need training. I just need someone to tell me this is how to file your taxes the right way for the right amount of money because it's something I do just kind of tangentially once a year, and I don't need to be able to apply it in all these different circumstances. I just need to know how it applies to me.
Now your company when it comes to compliance, you're the tax guy. You need to have that education in compliance— that's your core job duty, and you need to know the ins and outs of how it applies to all these different circumstances. But your employees don't. They do not need to be compliance professionals.
They need to be compliant salespeople, and compliant marketers, and compliant engineers, and so on. So they don't need to be educated on the elements of a compliance program or risk frameworks. What they need is to be trained on how to manage the fixer that they hired, and how to review a channel partner’s spend of marketing funds, and how to talk to a competitor at a conference without getting into trouble. You are never going to turn everyone at your company into a compliance professional.
But what you can do is help them do their own job compliantly. And you do that when you focus on training them instead of providing them with education.
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The reason the tax analogy works is it helps us get out of ourselves and realize that:
(1) there are a lot of compliance areas that are not traditional "compliance and ethics" issues; and
(2) for a lot of them we just want to be told what to do, and that doesn't mean we're not interested in doing the right thing.
This is especially helpful if you're really big into "values" talk.
Values are definitely critical, but I've noticed that folks who are big on on this can get locked into this belief that everyone should want to be a compliance officer, and that leads to this sort of paralysis where you don't want to give employees any practical advice for fear that they'll take advantage of it.
Imagine if that's how your tax guy treated you: that every time you asked if something was deductible, he gave you this droning, moralizing speech about doing the right thing and then just told you a bunch of principles without actually answering your question.
You'd probably learn pretty quickly to get a new tax guy.
And similarly, a lot of employees learn pretty quickly to ignore or end-run their compliance team.
Embrace the fact that wanting to "do the right thing" sometimes means asking what that is, and responding to that means giving folks practical training that tells them what to do.