High-risk employees often know where the real vulnerabilities are, because they live them every day. That’s why the U.S. Department of Justice’s Evaluation of Corporate Compliance Programs asks four questions on risk-based training directly:
- What training have employees in relevant control functions received?
- Has the company provided tailored training for high-risk and control employees, including training that addresses risks in the area(s) where misconduct occurred?
- Have supervisory employees received different or supplementary training?
- What analysis has the company undertaken to determine who should be trained and on what subjects?
Global enforcement agencies may phrase it differently, but they want the same thing: assurance that your riskiest roles aren’t getting generic, one-size-fits-all compliance training.
But here’s the bigger picture: when compliance leaders engage with high-risk employees directly—not just their managers—they can uncover gaps between “what’s on paper” and “what actually happens.” That insight isn’t just good for regulators. It’s good for business. It reduces mistakes, removes friction from critical processes, and builds trust between employees and compliance.
What do we mean by “high-risk”?
It depends on your business.
- Universal examples: employees handling money, interacting with government officials, or both.
- Contextual examples: roles defined by your annual and ongoing risk assessment. In healthcare, it could be providers entering billing codes. In tech, it might be engineers with access to sensitive data.
The question to ask is:
- What are the greatest risks at your organization?
- What are people trying to do when they encounter those risks?
- What problems are they trying to solve, and what tasks are they trying to complete?
That’s where training needs to focus. Not on abstract policies, but on the real decisions employees face every day.
Training in three levels
Level 1: Getting started
- Identify high-risk employees. Start with your risk assessment, then map exposures back to specific functions and roles. Use the org chart to see where these employees sit, how large those populations are, and who manages them. Layer in geography and seniority, since exposure often shifts by market and authority level.
- Meet with them directly. Don’t just rely on SOPs—shadow employees or host focus groups to see how the work is actually done.
- Introduce eLearning with branching. Route learners to the topics most relevant to their role and risk profile. Adaptive principles keep lower-performing employees in simulation until they reach proficiency, while allowing others to move quickly once they demonstrate mastery..
Tip: Training only needs to be as long as it must be. Unless a regulation requires a set duration, prioritize efficiency and relevance.
Level 2: Building sophistication
- Use insights from direct engagement. The workarounds employees create to get the job done may point to weak controls or inefficiencies. Capture these through shadowing, conversations, or process reviews, and use them as opportunities to both tighten compliance and improve workflow.
- Add quick-reference tools. Provide short-form guides, checklists, and scenario cards that employees can access in the flow of work—not in a training library they’ll never open.
- Provide concise, role-specific training. Deliver microlearning or short refreshers tied to high-risk decision points. Place these resources where employees already operate (intranet, workflow tools, apps) so they’re available at the moment of need.
Level 3: Expert practice
- Triangulate with business outcomes. Compare training data to operational metrics (errors, near misses, reporting), transactional data (sales exceptions, procurement approvals, payments), and audits. This helps you see if training is reducing real-world risk.
- Continuous feedback loop. Link simulation results with actual outcomes over time to identify persistent skill or judgment gaps.
- Embedded compliance. Integrate training, reference materials, and decision tools directly into business systems and processes.
At this level, compliance training becomes less about “checking the box” and more about enabling confident, ethical performance where it matters most.
Measuring effectiveness
You can’t just “set it and forget it.” Effective programs measure training in two ways:
- In-course performance: Simulation data shows whether employees can apply the rules in realistic scenarios. Adaptive learning highlights where individuals or groups are struggling and where they’re demonstrating mastery.
- Real-world metrics: Look beyond completions to the data streams that reveal whether training is changing behavior:
- Helpline and case management data—trends in questions, concerns, and substantiated cases.
- Transactional and monitoring tools—spend data, third-party approvals, or red flags surfaced by data monitoring and automation software that detects anomalies.
- Operational outcomes—quality checks, error rates, and near misses in high-risk functions.
- Audit and review findings—recurring gaps or control breakdowns that signal where knowledge isn’t translating into practice.
Together, these insights help compliance leaders refine training, adjust processes, and prove both risk reduction and business impact.
Closing thought
Training high-risk employees is one of the most visible ways regulators assess your program, but it’s also one of the best opportunities to add business value.
When compliance leaders meet with high-risk employees, listen to how they really work, and deliver adaptive, embedded training, the payoff is clear: fewer mistakes, faster processes, stronger trust, and a culture where doing the right thing is the easiest thing.
Harper Wells is a governance, risk, and compliance leader with over 20 years of experience developing enterprise-wide ethics and compliance programs. As Chief Compliance Officer at Learning Pool, she leverages data-driven insights and innovative training strategies to foster ethical, high-performing workplace cultures.
