Last year, one large European investment bank revealed that its employees spent twice as much time in compliance training last year as in 2010. In total, hundreds of thousands of hours had been committed to compliance training modules, said the CEO. That’s a lot of time, and it is only going to get longer.
Compliance training needs to become more intelligent. The compliance breaches at Barclays, HSBC and most recently Standard Chartered have aptly demonstrated the need for a new approach to compliance in the front office.
So what has gone wrong in terms of compliance training in the past?
First of all, the reliance on the word training is too one-dimensional. Training is typically focused solely around new joiners, major regulatory change or repetitive training courses that are mandated by regulation (for example anti-money laundering). Outside of this, the only other time compliance engages with employees is the annual compliance attestation; asking employees to confirm that they have read the compliance manual, spotted any changes and fully understood it!
This approach is too limited and what firms need to consider is a continuing cycle of raising awareness and building a culture of compliance.
Most bankers see compliance training as simply the firm discharging its regulatory liabilities rather than protecting the employees. This view is reinforced by the box-ticking nature of training and the ‘faceless’ annual attestation.
It need not be like this. If you’re drowning in compliance training or struggling to find the relevance of the mandatory compliance modules, there are alternatives.
It helps, for example, to have a ‘test-out’ approach. This exempts you from attending repetitive training sessions if you score above a certain mark. It can also help to communicate key compliance information in smaller chunks. People remember information for longer if it is short, meaningful and presented to them two or three times via different channels. It can also help to use online assessments that identify your areas of weakness and give you additional tuition to fill the gaps.
The aim of compliance training is not to immerse you in hours of regulatory torpor, but to raise your awareness and protect you from litigation from the FSA. Done properly, compliance training is in the interest of everyone.