Beyond the Checkbox: A Compliance E-Learning Case Study

Beyond the Checkbox: A Compliance E-Learning Case Study

In this compliance e-learning case study, Terry Hall, Head of Compliance & MLRO for Ebury in DACH, explains why compliance training is often perceived as burdensome and ineffective. He also discusses how microlearning provides an interactive and flexible approach to learning and the value it delivers to compliance training and the business. He shares a first-of-its-kind experience: a moment when a business-side colleague approached him to ask, “Hey, where’s my compliance training?” Read on to discover more.

tl;dr about Microlearning for Compliance Training

  • Compliance training is often seen as a burden and not delivering any value to employees.
  • Companies often seek the path of least resistance to achieving this goal, resulting in generic, off-the-shelf content.
  • This compliance e-learning case study shows how microlearning, specifically chat-based microlearning, is a more engaging and interactive way of training that can increase the number of people who listen and engage with the material.
  • Microlearning overcomes the hurdles of classic online modules and bypasses the need to find an hour in the day.
  • Microlearning also allows for different preferences of learning and cognitive reinforcement.
  • The value of putting in time and effort to create a tailored training module is worth it, as it leads to increased engagement and retention.
  • Although it is challenging to put a monetary value on it, reminders about compliance can prevent potential fines.
illustration of a fully booked calendar on a notebook screen
Professionals have busy schedules but “everybody has time for a microlearning break”.

1. The Flaws of Checkbox Compliance: Why Generic Training Fails Employees and Businesses

We asked ChatGPT to act as an employee of an average company and gave it one wish it has when it comes to compliance training. It said: I wish training to be more engaging and interactive including real-world scenarios and opportunities for hands-on practice to help me understand the material better and apply more effectively in my work. Why do you think it expressed that wish?

It’s scarily accurate. For a lot of employees, compliance training is indeed seen as a burden as we highlight in our compliance e-learning case study. It can be viewed as not delivering any value and not adding anything to their jobs. It’s just a tick-a-box exercise. Most people know, If I don’t do it, my line manager is going to receive an email and come tell me to do it.

Compliance training is intended to ensure that employees are well-informed about the risks in the compliance field, including money laundering and bribery, among other topics.

Ensuring employees are aware of these risks lead businesses to implement well-intended compliance training programs. However, companies often seek the path of least resistance to achieving this goal.

Nearly everybody ended up with a platform that provides generic, off-the-shelf content, which we can send out globally to everyone, and they can complete it in an hour. Then we repeat it every January, and we can proudly claim that we’ve completed annual training on that topic.

This approach inevitably means that not many companies take the time to tailor the training content for their specific needs, as it requires intensive work.

In addition, in larger organizations, compliance training is often created with one jurisdiction in mind, resulting in content that’s not tailored to the specific location or job role of the employee. As a result, you’re making compliance training even more generic.

Employees are immediately kind of annoyed. Not many have that spare hour just lying around. They might have to skip lunch, start early or finish late. It’s an interruption to their usual routine.

As employees didn’t volunteer for compliance training and approached it with the mindset that it is a burden and not directly relevant to their jobs, it’s not going to be something that they cling to. Quickly after the training, what was learned is lost and forgotten.

The final point to consider is that in the past year or so, several major audit firms have been fined due to their auditors cheating on internal training assessments related to ethics, conduct, and proper behavior. These individuals were taking screenshots of the answers and sharing them with others. It’s unfortunate, but human nature dictates that if a task is perceived as a mere checkbox to tick off, and there’s an easy way to do so, many people will opt for the path of least resistance. Even if it involves cheating.

2. Striking the Balance: Tailored vs. Generic Training

We also requested ChatGPT to serve as a head of compliance and asked for its perspective. It said it wishes that all compliance training materials are tailored to the specific needs of each employee making the training relevant, engaging and easy to understand. Is there anything else that needs to be added?

That’s a very idealistic viewpoint – and where an AI model hits its limitation. In the real world it’s impossible for the vast majority of businesses to have a training plan which is individually tailored for every employee – just think about how many different roles there are in an organisation.

You need to have a mix of different methods and tools to effectively train employees. Everyone learns in different ways, and cognitive reinforcement is crucial to ensure that the message is absorbed and retained.

Even if it’s something you’ve only heard once before in your life, if you hear that same thing repeated, you still get a little bell that rings in your mind, and you think, “I’m sure I might not know where, but I’ve heard that before.” It’s the way that the brain retains knowledge – the electrical pathways it follows to go from one piece of information to another. The more that pathway is used, the more familiar you become with the information.

From that perspective, finding different ways to repeat the message without completely disengaging the person receiving the message, I think, is probably the right way to go. I would agree with tailoring to a point, which is that it should be specific to our business, the jurisdictions and cultures we operate in. If it’s generic to an entire industry sector, it’s probably not relevant enough to be useful.

For our use case, there’s no reason that we can’t have an AML module that is tailored to be relevant for the payment services industry in Switzerland, as opposed to a generic AML module that talks about financial services and is global. There’s a very different value proposition between those two training modules, and there is work involved in taking a generic financial services global module and tailoring that to become a payment services Switzerland module. But the value you get for that work is huge, and that’s not an unachievable dream.

The online module serves a purpose, and unfortunately, to a degree, the purpose it serves is there’s a line in regulation that says we have to do it, so guess what, we have to do it. But then, I want it to be effective, so that means that I follow up and repeat the key messages.

Terry Hall
“I want Compliance Training to be effective, so that means that I follow up and repeat the key messages.” Terry Hall, Head of Compliance & MLRO for Ebury in DACH.

3. Microlearning for Compliance Training

How does microlearning fit into such a training concept?

When we met at the Apéro arranged by a mutual business connection, you mentioned your work in microlearning. I was excited because it’s a concept I’ve been exploring as a way to increase engagement rates in learning.

What I like about Microlearning: It overcomes the hurdles of classic online modules and bypasses the need to find an hour in the day. It only takes two to three minutes to complete. Everyone has those two to three minutes multiple times during the day. Some take a bathroom break or a coffee break or a cigarette break or a microlearning break.

Microlearning also allows for different ways of learning and cognitive reinforcement. I can take the five-minute stand-up on a key theme from my training module and put it into a format that is worded exactly how I want it to be. I find it more powerful to deliver messages in a chat format that people can easily retain. Overall, micro learning is a more engaging and interactive way of learning that can increase the number of people who listen and engage with the material.

All the feedback we get about the chat-based microlearning approach is incredibly positive. The organization I’m currently working with has a strong sales focus. Our team members are wired to quickly absorb information and move on to the next task. Microlearning is the perfect tool in this context because it doesn’t disrupt their usual way of working and fits seamlessly into their routine. They can come in, get the information, and go, which is exactly what we need.

4. Chat-based Microlearning for Compliance Training

You are into a specific type of microlearning that uses a chat-based and conversational approach. How do you implement it, and what kind of feedback do you receive? How does this approach differ from other methods?

The way we have applied it is by preparing our own chat-based conversational journey. It involves about three minutes of chat interaction between the user and the chatbot.

It’s an interactive experience for users. They have options and the flexibility to choose how to respond to a certain chat bubble, but ultimately the chat follows a path and leads to a goal that’s important for us. Overall, this makes it feel a bit more personal. I’m probably doing your sales pitch but the tool that you have given us is super powerful. You can add emojis, gifs, and short video clips, which can make it quite engaging and grab people’s attention, keeping them interested in moving to the next step of the chat.

We have selected specific elements of our policy or regulations that are the most critical and important. These elements are like the big red button that we want people to be able to press if the situation requires it.

So, the approach is not suitable for providing a general overview of the money laundering rules in Switzerland as it’s too broad of a topic and cannot be covered in just a few chat-interactions. However, it can be used to address specific elements or exemptions within the rules. For example, when a company is considered well-known and what actions need to be taken in that case. By focusing on one specific rule, the microlearning approach can be highly effective.

Another example: to provide an update on the new revision of the AML act, you can easily summarize two or three key topics and explain how it impacts our policy in a chat format. This is because people may have seen news or read about the changes but may not know how it affects their day-to-day work. It’s not always a simple topic to understand, and including it in annual training modules might be too late, especially if the changes occur the week before the training. Therefore, a chat-based microlearning format can be a more effective and timely way to provide updates on changes to policies or regulations. The chatbot is particularly useful for ad hoc updates like “this has happened, this is what it means”.

professional engaged in chat-based compliance training
Finding a way to make compliance and regulation an entertaining topic for people to engage with and to take away the key messages is powerful.“, Terry Hall

If you have a very specific and niche piece of information that is directly relevant to your business, you can use this format to deliver it to people. I select something that was included in my one-hour module or face-to-face training. People know, it was covered before, but hearing it again for a third time in a different format, like through the chat-based microlearning approach, increases the likelihood of it being retained in their memory. So, when employees encounter a similar situation in real life, they will recall having heard about it before. For us it’s about increasing engagement by using a different channel for that one core piece of information.

The feedback we’ve received has been really positive. People have engaged with the topics and found the method to be enjoyable. Let’s just call it what it is, a fun way for people to learn. This is great because it makes it easier for them to get information that is typically not seen as interesting. I chose this profession and work with compliance and regulation, but for most people compliance, regulation and fun don’t normally land in the same sentence.

We had a meeting today with the Country Manager for the Germany office. We have recently expanded to start using these e-learning chatbots for Germany as well. During the meeting, he asked us when the first chatbot will be available. He mentioned that he hasn’t seen his chatbot yet and was curious about when he will receive it. It was quite surprising for us to hear someone from the business side inquiring about their compliance training. I’ve never experienced someone on the business side coming to me: hey, where’s my compliance training.

Finding a way to make compliance and regulation an entertaining topic for people to engage with and to take away the key messages is powerful.

5. Fun and fear in compliance training

You mentioned the aspect of fun. Does compliance training have to be fun?

I believe that making compliance training fun is important, and it’s about finding ways to make it enjoyable. Compliance training can be made fun and engaging. It depends on the context. When it comes to general compliance training, it can be made as fun and engaging as needed. You can get people in the room, have some laughs, and present the information. However, if something has gone wrong, and there are big problems, the training afterward will likely be less fun.

Compliance training doesn’t have to be fun, but it definitely can be. It depends on how well you know the subject and how you can tailor the training to the audience. Sometimes however, you have to bring out the big stick and tell people the rules and why they exist.

What effect does it have when you threaten people or cause fear?

I don’t know how helpful it is, but sometimes you have to do it for two different reasons. Firstly, because some people don’t take things seriously, and you have to show them the potential deterrent and punishment for them to realize how serious the topic is. Secondly, depending on the jurisdiction, auditors might be super strict and demand evidence of where you informed someone of the potential prison sentence if they commit a crime inadvertently. Therefore, having this information in your training is necessary to meet audit requirements. However, I’m not sure how effective this approach is. If the threat of punishment was enough to educate people, nobody would ever break the law. But that’s not the case; there needs to be something else.

In my opinion, the most powerful reason why people comply with any rule is that the rule makes sense and feels like the right thing to do. That’s why we emphasize ethics and integrity in our induction training. In just half an hour, we can’t cover all of our policies and regulations. It’s too overwhelming, and people will drown. Instead, we focus on the message that if something feels wrong, they should come and talk to us. That’s a message they can take away and apply to their job. If they get that right, then 99.9% of everything else will work out.

Therefore, I don’t hammer home the message of the potential criminal penalties they could face. I might use it as a little joke now and then, but generally, I don’t focus on it. Fear isn’t a powerful motivator.

6. Chat-Based Learning: When It Works, When It Doesn’t, and Why Simplicity Matters

How would you describe the limitations of chat-based microlearning? In what situations would you not apply or recommend using it?

I believe that for chat-based microlearning to be effective, the concept must be relatively simple. If it becomes too complicated with multiple layers and variables, it can become overwhelming and fall apart. The linear nature of the conversation is what makes it intuitive, as it guides you step-by-step through the topic. However, if you have to refer back to previous steps to understand later ones, you lose the flow and the benefits of the linear conversational format.

That being said, I think that on any given topic, it is possible to find simple, key messages that are powerful and effective for chat-based microlearning. For instance, questions like “what’s my reporting threshold if someone offers me a gift?” or “how do I report it and who do I need to send it to?” can be easily addressed through this format.

Is it difficult to create such a chat-based learning nugget?

It is easy to write a chat that simply goes back and forth, but this may not necessarily engage the audience. Creating a chat that is truly conversational and interactive is not an easy task. It requires careful planning and execution to ensure that the chatbot is engaging and feels like a real conversation. When building my chatbot for the first time, I may have been too ambitious with too many different options, which made it complicated. However, with experience, it becomes easier to create a chatbot that is engaging and interactive, and takes the audience on a journey through the conversation to learn information.

The value of putting in time and effort to create a tailored training module is worth it, as it leads to increased engagement and retention. Analytics show a low dropout rate, indicating that people start and finish the chatbot, unlike long training modules where people may lose track and forget to complete it. Engagement and retention are the main benefits of using chatbots. By analyzing the data, we can see that people remember and are aware of the topics covered in the chatbot.

7. The ROI

Is there a way to express this value in terms of money?

Let’s call it that: the goal is to avoid conflicts. When we break regulations, we run the risk of monetary penalties. Yet, it’s almost impossible to pinpoint the monetary penalty we avoided to a chatbot training we did in March 2023. Drawing that direct parallel is near impossible.

However, the value we did get was the insight that people didn’t pick up key messages from the classical annual online module. Reinforcing those messages with chatbot training was valuable. For instance, we received a pie chart from analytics that showed only 40% of people picked the right option on the threshold question, which we had covered in a one-hour training. Within five weeks, 60% of people had forgotten the information. This information was beneficial because it allowed us to reinforce the message to our employees in Switzerland and pass it on to the group level. They are not using the chatbot yet, so I suggested they send reminders about the threshold.

Although it’s challenging to put a monetary value on it, reminders about the threshold may prevent potential fines from not reporting on business lunches attended six months ago. The value gained is not tangible, but it’s still valuable.

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