This is part 3 of a 5-part podcast series with Tom Fox and the FCPA Compliance Report on Culture, Training, and Compliance. Listen to the series from the beginning.
Where do meeting compliance skills development and regulatory requirements intersect?
In any regulatory guidance, whether in the United States or abroad, training is considered by regulators to be one of the pillars of a Bank Secrecy Act (BSA) compliance program. This is especially critical when providing training to the first line of defense. Who knows clients better than the front-line bank officers who deal with them on a regular basis? The role of a compliance professional is to ensure these front-line employees are provided with the appropriate tools so they in turn will to be able to perform their duties. This is done through a robust and comprehensive training program.
Additionally, regulators are looking at the skills and career paths of bank employees. Do the employees in their specific roles have the right set of knowledge, skills, and expertise to carry out their compliance responsibilities? This scrutiny has moved beyond strictly compliance-related roles to business-oriented roles as well. For example, in areas such as private banking, loan departments, trade finance functions, and correspondent banking departments, examiners will sample and check what experience and skills such employees have and what type of training they have received. Thinking critically about whether the employees in key roles possess the right set of skills and expertise should guide institutions as they develop their training programs, especially their long-term programs.
A very important aspect of compliance training is educating employees that training is not a form of punishment but actually a valuable tool that not only helps them do their job right but also serves to protect the bank, its clients, and its employees.
Today, there are better systems for e-learning and training solutions to ensure people are actually taking and completing these trainings. These systems can track training completion, check the number of tries for passing the exam, and even send reminders. Finally, institutions are moving toward more bite-sized training (See: Espresso Training Shots). This can lead to training that doesn’t take up an entire day or week but that can fit within the regular workday; and this is even more applicable in today’s environment where most of us are working remotely, either full-time or in hybrid mode.
