Fcpa Compliance Report

The Justice Department Evaluation of Corporate Compliance Programs states the following around training: Training and Communications Risk-Based Training – What training have employees in relevant control functions received? Has the company provided tailored training for high-risk and control employees that addressed the risks in the area where the misconduct occurred? What analysis has the company undertaken to determine who should be trained and on what subjects? I thought about the requirement for tailored training and how this leads to operationalizing your compliance program. Consider the current best practices to tailor your compliance training. It is through a risk ranking system of employee job duties or positions which is usually done by someone from the corporate compliance function reviewing lists of employees and then matching up their job duties, focusing on those involved in international operations which have foreign government or state owned enterprise touchpoints. Most usually it targets emp