You think horror movies are scary? Try reading this article from Nate Dvorak at Gallup. He presents...
2 minute read ·
[Video] Three dumb compliance training myths (that everyone falls for)
The compliance training space is DROWNING in stupid, corrosive, credibility-shattering myths. So let's bust some of 'em!
In today's video, we kick off with some rapid-fire busting of a few particularly dumb learning myths—and then we spend the most of the video going deep into three dumb myths that lawyers fall for.
Because the biggest threat to your program isn't dumb behavioral myths, but dumb myths that lawyers believe.
I mean: yes, the behavioral myths mean you'll get suckered into buying a bunch of dumb stuff, but that's just money; you can recover from that.
The lawyer stuff, though ... if your CCO or General Counsel believes dumb myths like "prosecutors only care about records" or "we have to start with Code of Conduct training," you're dead in the water.
So watch—and then give it to a lawyer you love.
Correct, that is a fart noise playing when I bust the behavioral myths at the beginning. They're just so dumb that it felt right. And if you've never listened to a whole bunch of stock fart sounds to find the one that is "just perfect," it's, uh ... a thing you can do.
And yeah, this is a real problem: each of those three fart-worthy myths has actually been used by a compliance training vendor.
Here are the sources for the images I show when we're talking about the behavioral myths:
And finally, let me unpack what I mean when I say "I get that" about folks taking a "just in case" approach before the Evaluation of Corporate Compliance Programs.
Because no, I don't think that the law firm approach of "train everyone just in case" was good or useful or smart.
It was stupid and wasteful and reflected a desire to avoid liability instead of actually preventing misconduct, which is a betrayal of what the compliance job is supposed to be.
At the same time, the DOJ wasn't really any help here in the past. A lot of folks relied on that Morgan Stanley NPA to justify all this stuff, which was an absolute trainwreck of a document but was at least a document and not a speech or scuttle from a former SEC or DOJ prosecutor-turned-law-firm-partner that you had to hire to tell you what the government really meant.
Was that smart? No. But understandable. Dark times.
But not anymore! The Evaluation of Corporate Compliance Programs is crazy clear on this stuff. And our interview with Hui Chen couldn't be more explicit.