Should you use "out-of-the-box" FCPA training?

Yes, but only with careful customization.

The US Department of Justice (DOJ) requires that companies have "effective" compliance programs. To have an effective compliance program, employees need to (1) understand the company's policies on topics like anti-corruption, antitrust and harassment and (2) take appropriate actions based on the policies' requirements. 

How do you get employees to understand and implement your company's policies?

Effective training.

What is "effective" training?

Effective training is more than requiring your employees to read through a bullet-point-heavy PowerPoint presentation once a year;

Effective training is more than using a PowerPoint presentation you got from outside counsel;

Effective training is more than "out-of-the-box" training.

In order to create effective FCPA training, you must specifically tailor your training materials to the situations your employees will actually encounter.

Regardless of how a company chooses to conduct its training, however, the information should be presented in a manner appropriate for the targeted audience.
— US Department of Justice - FCPA Guide

Does this mean that you shouldn't use "out-of-the-box" solutions you get from service providers or outside counsel?


It simply means you need to modify "out-of-the-box" FCPA training materials to fit your company's needs.

For example, if your company doesn't do any direct government bids, you may want to avoid a heavy focus on this area in your training materials. 

In a perfect world, in-house counsel would have plenty of time on their hands to create training from scratch. But, we live in the real world where there's often not enough time to create amazing FCPA training materials from nothing. 

My advice - start with  "out-of-the-box" FCPA training materials to save yourself hours and hours of time. Compare it against other resources and guidelines. Then, adapt it to your company's needs. 

If you're unsure on where to find an engaging "out-of-the-box" FCPA training package to start, check out our Instant FCPA Training. It's as close as you'll get to a complete "out-of-the-box" solution to your FCPA training needs, but it's also editable, so you can modify it to create effective FCPA training for your company.

Click on FCPA Training to get check it out


Regardless of what you choose to begin your journey to effective FCPA training, check out our free DIY FCPA Training Guide.