On more than one occasion I have had someone tell me that Americans are a bit crazy about compliance.

 This statement is usually followed by an explanation that, while the employee understands what the company expects of him, compliance is really just an “American” thing—that local employees of an overseas unit don't worry about compliance nearly as much as the U.S.-based parent does. From my discussions with compliance officers at other U.S. companies with businesses abroad, I know that this experience is not particularly unique.

Effectively selling the value and the reasons for American-style compliance is a continuing challenge for compliance professionals of U.S. companies that operate globally. International employees often view American compliance as completely detached from the realities of the local market—a nice to have component, that is when it doesn't get in the way of business in accordance with local cultural norms. While there is no magic solution to winning over employees in faraway places on the value and importance of American compliance training, there are some steps that companies can take to increase the likelihood that compliance messaging and lessons will be embraced in these local regions.

Gain the support of local leaders: For compliance training and communication to effectively resonate with employees outside the United States, it is absolutely critical to gain the buy-in and support of leaders in the local office. Compliance officers should take the time to meet with these leaders; ask questions to gain a full understanding of the business issues and challenges they face; and solicit feedback about the company's approach to compliance and ways to effectively promote compliance goals locally. Engaging local business leaders and working on compliance solutions together helps ensure their enthusiastic support of the company's compliance efforts and increases the likelihood that these leaders will help set the tone for the rest of the office. Engaging local business leaders in developing compliance programs can change the perception that compliance demands are coming down from afar and improves the chance that those leaders will champion their implementation. Everyone expects compliance officers to promote the company's compliance program, but when the local business leaders are the ones delivering compliance messages employees pay much closer attention and are more likely to tailor their actions in accordance with these messages.

Localize your messages: One of the biggest mistakes that U.S. companies make when pushing compliance communications and training to a global workforce is not taking the time to ensure they reflect the global nature of the company's operations. Too often, compliance training and communications are U.S. centric, meaning they are provided only in English and many times only with references to U.S. laws, regulations, and customs. This approach, rather than promoting the company's compliance efforts, often helps fuel the notion that compliance is strictly an “American thing.”

There is no substitute for the instant feedback that comes from live interaction with employees and the ability to see, first hand, whether they “get it” or not.

To help overcome this challenge, companies should, whenever possible, include references to local laws and customs in compliance-related training and communications. Using real-life scenarios that reflect the local culture helps employees better understand the lessons being taught and how such lessons can and should be applied when conducting business in their own country.

Not lost in translation: There are a number of relatively simple things that companies can do to globalize compliance training and communications.  More and more compliance training offered by third-party vendors is customizable, allowing courses to be modified to include references to local laws and customs, and to provide for spoken or subtitled translation into multiple languages. Even at companies where employees outside of the United States have a good command of English, taking the time to translate compliance-related materials – including training, communications, and the company's Code of Conduct – helps ensure the highest level of employee comprehension. It also supports the notion that good compliance is not just an American issue, but a global issue that is important to all of the company's employees, as well as the success of the company's global business operations. Note too, that regulators have on occasion cited companies for providing compliance training only in English as part of the justification for stiffer penalties on a particular compliance offense.

Boots on the ground: Companies should also work to ensure that at least some of the training and communications provided to employees is not only done in the local language, but is done live. This local training can take many forms—from formal sessions with different teams across your business to informal “lunch and learns.” The important thing is to ensure that critical compliance-related information is being delivered to employees in their native language and that employees have the opportunity to ask questions and seek clarification about the information they are receiving. There is no substitute for the instant feedback that comes from live interaction with employees and the ability to see, first hand, whether they “get it” or not.  

In most companies, employees in “gatekeeping” functions such as the legal department and human resources are obvious candidates to deliver such training. Companies should take the time to engage local leaders of the business to ensure full support and participation from employees in these live training sessions. To put this into practice, an annual performance goal of all the company's lawyers at CA Technologies is to conduct at least three live training sessions on a compliance-related issue relevant to the local workforce. The feedback we have received from employees about these live training sessions has been overwhelmingly positive and the compliance team has gained valuable information about employee concerns and levels of understanding of compliance concepts from questions asked and feedback provided during these sessions.

The importance of travel: Chief compliance officers spend a good deal of time marshaling limited resources to address numerous compliance-related issues: investigations, policy development, training and awareness, risk assessment—the list goes on and on. Often lost in this morass is adequate budget to allow for meaningful travel, something that is critical to the success of a global compliance program.

When companies are looking to tighten up spending, one of the first places they look to make cuts is in their travel budgets. While the elimination of unnecessary travel expenses is a sound way to address potential budget shortfalls, companies should exercise extreme prudence when making these cuts, so they don't have the unintended effect of weakening the company's compliance efforts.

One of the best ways to build a strong compliance foundation is by building relationships with leaders within the company. In today's digital age, while it is certainly possible to build relationships through phone, video conference, and e-mail, it is much easier and more effective to build such relationships when you can sit in the same room with a person, learn about them, share a meal, get to know them, and reach an understanding of their business concerns and challenges.

A compliance program that finds ways for its officers to be visible to employees in locations around the world also reinforces the importance of compliance as a global concern, reinforces the importance of employees around the world in driving the company's success, and helps promote the type of “speak up” culture that we all strive to achieve in our companies.

Building a truly global compliance program that a global workforce will embrace is not easy and will not happen overnight. However, if you find the time and resources to devote to implementing some of the suggestions above, it will go a long way to help overcome the notion of compliance being a “crazy American” kind of thing.