How does the requirement for tailored training lead to operationalizing your compliance program? Consider current best practices for tailoring such training, such as a risk ranking system of employee job duties conducted by someone from the corporate compliance function who reviews lists of employees and then matches up their job duties, focusing on those involved in international operations with foreign government- or state owned-enterprise touchpoints. This would likely target those employees operating within the sales function. 

Thomas Fox has practiced law for over 40 years. Tom writes the daily award-winning blog, the FCPA Compliance and Ethics blog and founded the Compliance Podcast Network. Tom leads the discussion on AI in...