FCPA

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

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?

The Ultimate Guide to 45 Minute FCPA Training

The Ultimate Guide to 45 Minute FCPA Training

What if you only had 1 hour to teach your employees about the anti-bribery regulations found in the US Foreign Corrupt Practices Act (FCPA)?

I usually reserve at least 25% of the time for questions and conversation, so now you're down to 45 minutes. 

Given the ambiguity of the FCPA, it's not immediately apparent which topics corporate counsel should cover more in depth in their legal training presentation. Realistically, it might take 4-5 hours to give employees a presentation covering every example of an FCPA violation. 

As we've previously covered in the InHouseOwl Ultimate Guide on Antitrust Training, and the Ultimate Guide on Advertising Law Training, corporate counsel need to start with the basics. What do employees need to know? And when do they just need to spot a red flag and report back to legal?