Who Needs to Be Trained?
Everyone. Sections 8B2.1(b)(4)(A) & (B) of the Federal Sentencing Guidelines reference the need to train the entire workforce with a sweeping definition of “individuals” who must be trained: The organization shall take reasonable steps to communicate periodically and in a practical manner its standards and procedures, and other aspects of the compliance and ethics program, to [members of the governing authority, high-level personnel, substantial authority personnel, the organization’s employees, and, as appropriate, the organization’s agents] by conducting effective training programs and otherwise disseminating information appropriate to such individuals’ respective roles and responsibilities. This requirement is further underscored in the Commentary to the Amendments: Section 8B2.
