FCPA Training That Works: An Interview with Joseph Spinelli, Global Leader of Navigant’s Anti-Bribery & Corruption-FCPA Segment

Designing and implementing a workable and customized FCPA training program is a foundational challenge in anti-corruption compliance for all companies doing business internationally.  As the FCPA Resource Guide says, “Compliance policies cannot work unless effectively communicated throughout a company.”  As a practical matter, training is the primary channel through which companies communicate their culture of FCPA compliance and specific compliance strategies.  Done right, training is one of the most effective bulwarks against FCPA violations.  But how can companies do training right?  To answer this question, the Anti-Corruption Report is undertaking a series of interviews with experts that approach the same topic (FCPA training) from different disciplines.  This article – the first installment in that series – includes our interview with Joseph Spinelli, a Managing Director in Navigant’s Global Investigations and Compliance practice and the global leader of Navigant’s Anti-Bribery & Corruption-FCPA segment.  Spinelli has more than 30 years of forensic experience, founded the forensic practice at a Big Four accounting firm and has served in various monitorships.  See “How to Find a Business-Minded Compliance Monitor and Minimize Reporting Requirements When Negotiating an FCPA Settlement (Part Three of Three)” (Mar. 20, 2013).  Spinelli shared his views not only on how to make a training program effective in preventing bribery, but also on how to ensure the company receives maximum credit when the government is evaluating its training program.  He addressed, among other things: training third parties; which employees should be trained; specialized training for different industries; the relative merits of different technologies for training employees; training challenges, including facilitation payments; and effective training methods.

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