What does "effective" compliance training look like?
Do we need to do in person training?
Who should be trained?
And how often?
Answering these questions is critical to create an "effective" compliance program in line with the US Federal Sentencing Guidelines (which ultimately could prove to mitigate fines incurred by companies which are prosecuted by the DOJ). Unfortunately, there is no "one size fits all" solution, and the Department of Justice (DOJ) hasn't given many real world examples of "effective" programs.
But now for the first time, the DOJ has provided insight into what makes a corporate compliance program effective enough to earn a recommendation for a lower fine under the Federal Sentencing Guidelines.