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.
This type of analysis, however, does not fully tie the calculus of Foreign Corrupt Practices Act touchpoints to the panoply of the prevent, detect, and remediate mandates of an operationalized compliance program. There are innumerable employees in every corporation who could be employed in the detect prong and who are generally not being engaged as a part of the compliance backstop.
