How should our training be structured?
Training is an essential component of your SCP to ensure that employees understand your company’s risk appetite, compliance structure, and policies and procedures used to achieve compliance.
We often see that organizations and suppliers of training materials focus on explaining in exhaustive detail the limitations and restrictions of sanctions under different regimes (eg. EU, US, ect.). However, this approach can often be counterproductive for most employees because they become overwhelmed with information that is not tailored to the realities of their daily work. The best focus for an organization’s training program is to ensure that all employees know their roles and responsibilities in the company’s SCP. This means that employees know where to escalate issues of concern, that they understand the company’s sanctions policies and risk appetite, and that they are able to apply the controls for their role, be it sales, procurement, logistics, and especially senior management. The level and detail of training should be based on each employee’s responsibility, so that employees from the entry level through senior management receive training appropriate to their roles and understand their responsibility for achieving compliance.
How often do staff need to be trained?
Training should be mandatory for all employees and provided at a frequency appropriate to the organization’s risk profile. At a minimum, all employees should receive the necessary training as part of the onboarding process, and an annual refresher which includes any updates or changes the company has enacted in the past year and new risks that your organization faces. Given that sanctions can change rapidly, as with Russia, it very well may be appropriate to provide trainings that are held more frequently for those employees that most often need to understand the changing landscape, such as those involved in sales or similar roles.
Your training program should be updated frequently to reflect changes in the sanctions environment, and should also be updated after learning of negative audit or test findings to ensure that personnel learn and continuously improve. The benchmark to judge whether a training is effective, is not a lack of sanctions issues experienced by the company, but rather an increase in the number of questions and issues raised by employees, demonstrating that personnel understand the company’s approach to compliance and are paying attention to high-risk activities.
Where can I find resources for my company?
There are many resources and materials available to companies from government entities, industry and trade associations, as well as conferences and seminars. The real challenge is taking these resources and making them appropriate to your specific company and this is where external experts such as ourselves can help. Even with the help of external experts it is still vital that there are personnel within the company that are able to manage the training program to ensure that training materials are appropriate to your organization and adding efforts for continuous improvement.
Your sanctions training should focus on:
- The risks specific to the company and its industry and the importance of maintaining compliance
- Indicators (red flags) to identify potential risks in the company’s line of business and specific roles
- The company’s compliance program and control framework, including the application of controls in specific roles and departments
- The points of escalation for issues and potential breaches of the company’s program and regulations.
Questions to ask to evaluate your organization’s sanctions training
- Do all our employees know how to contribute to sanctions compliance in their role?
- Are the employees demonstrating sanctions compliance knowledge in practice?
- Is training provided regularly/periodically?
- Is our training program updated to address lessons learned and changes in the sanctions environment?