The Department of Justice (“DOJ”) has commented that that they expect companies to foster a “culture of compliance” where all employees have been effectively trained about the laws they are required to obey. The DOJ has further indicated that such training should be held for everyone, “from the boardroom to the supply room” and for agents of the company where appropriate. The government specifically condemned “check the box” training programs and suggested that live training should be mixed with on-line courses.
Experience providing live FCPA training globally for over a decade. My training programs are designed to be dynamic sessions that encourage audience participation and go well beyond a mere PowerPoint presentation.
Additionally, I provide OFAC counseling for multinational clients and have successfully defended OFAC enforcement investigations.
Following a recent FCPA training, I was approached by a woman who told me that she had attended numerous FCPA trainings in her prior roles in a big four accounting firm and for one of the largest multi-national companies. She wanted me to know that the training session I conducted was the best she had ever attended.
There is sometimes the inclination to conduct FCPA trainings internally. There are number of reasons, however, that it makes more sense to hire outside counsel to conduct the training. Because you hope that your employees will not violate the law, you want them trained as thoroughly as possible. As a former federal prosecutor with significant experience developing and conducting FCPA trainings, I can not only provide the training, but I can also handle the unexpected real-life questions that a good training will elicit.
Providing employees with the type of training I conduct also acts as a type of insurance policy if an employee does behave badly. The government will want to know the steps you took to ensure that the employees understood the rules. The government does not consider budget constraints as an acceptable excuse not to train employees effectively.
I am confident that my experience conducting FCPA trainings throughout the world, including in Argentina, Brazil, Canada, Cayman Islands, Chile, China, Colombia, Germany, Ghana, Guyana, India, Mexico, Nigeria, Peru, Russia, South Africa, South Korea, Uganda, Ukraine, United Kingdom and the USA will be of benefit to your organization.