Since at least 2017, the DOJ has emphasized the need to determine compliance training effectiveness. In the 2020 Update, it stated under the section entitled “Form/Content/Effectiveness of Training” the following questions, How has the company measured the effectiveness of the training? Have employees been tested on what they have learned? How has the company addressed employees who fail all or a portion of the testing? Has the company evaluated how much the training impacts employee behavior or operations?

Three key takeaways:

1. You must demonstrate you have measured the effectiveness of your compliance training.
2. The DOJ is clearly moving into requiring a demonstration of the effectiveness of compliance training.
3. You should be moving towards a model demonstrating compliance training ROI to validate the full operationalization of your compliance training.

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