Menu11/3/2015: Tom Fox’s recent post on his FCPA Compliance and Ethics blog focused on the issue of “… training and testing the effectiveness of a best practices FCPA compliance program.” Employee training has always been an integral component of an effective compliance...program but Fox reminds compliance practitioners that the DOJ and SEC are not satisfied with “check the box” programs. In fact, both DOJ and SEC have sent out clear signals that having employees take tests and sign certificates saying they took the required training is not sufficient. So, what will satisfy DOJ and SEC? Fox suggests four actions that can help compliance professionals craft programs that are sufficient in the eyes of the top US enforcement agencies.
