Imagine you have a friend who is passionate about pancakes, while you’re more of a waffle kind of person. (Trust us: The compliance content is coming. Just keep reading.) Your friend starts telling you about the right ratio of wet to dry ingredients, why you should use buttermilk, and how not to overmix the batter.

When he’s done, you may know how to make the perfect pancakes, but you and your friend are no closer to sharing a position on the best breakfast food. Your friend was training you, not communicating with you. And, even more importantly, he wasn’t listening to you.

Does this pancake-loving friend sound like a familiar figure in the compliance world? Companies regularly train their workforces on laws, policies, procedures, best practices, and more. This is vital work, but it is only half the job, and many companies skip the other half, leaving communication out of their annual plans. (And no, emails notifying employees of required courses do not count.)

Training is not communication, and vice versa. The difference matters for the effectiveness of your program and under the Federal Sentencing Guidelines.

The U.S. Sentencing Commission delineates between training and communication in §8B2.1.(b)(4) of the Federal Sentencing Guidelines for Organizations (Guidelines). The Guidelines state that for an organization’s compliance and ethics program to be deemed “effective,” it must “conduct[ ] effective training programs and otherwise disseminat[e] information appropriate to … individuals' respective roles and responsibilities.”

That’s right: training and the dissemination of information. Two. Separate. Elements. Sure, some organizations and vendors will argue that training programs are communications, as well. But let’s come back to our very important breakfast food discussion to see the difference.

Your friend seemed to think that if you just understood all the steps that went into making great pancakes (which are, indeed, important), you’d understand his point of view. But what if your friend had first asked you what you like so much about waffles. Is it the aroma on a weekend morning? Is it the way the syrup catches in the squares? He then could have used what he learned about you to shape his message. He could tell you how amazing pancakes smell when they’re fresh off the griddle and how they, too, taste delicious with maple syrup. By listening to you and connecting with you, he is more likely to reach you with his communication. And, not for nothing, you might now be more open to understanding and absorbing his training on how to make great pancakes.

Communication is about persuasion. And persuasion always starts with understanding the person you’re talking to.

At Rethink Compliance, when we work with clients who are ready to add effective communication to their compliance programs, we start by listening — not only to our clients but also to their audiences. We dig into the experiences and attitudes of their workforces: What motivates them to do their jobs well? How do they make decisions? What are their underlying cultural assumptions and biases?

For many, this is a radical shift in thinking, and it can feel like an extra step. But think about who has been effectively convincing us to change our breakfast food preferences for more than a century. That’s right: the marketing and advertising industry, where audience research is the essential foundation for all communication.

Whether you prefer pancakes or waffles, you certainly understand that they are two related but separate breakfast foods. It’s time we started treating training and communication the same way.

At Rethink, we're so passionate about starting with the right communication strategy that we're including a Communications Playbook with all longterm library contracts. We'll help you research your audience, focus your messaging, and build a custom communication plan for bigger impact with your employees. Want to learn more or just chat about where your compliance and ethics program is headed? Contact us at or

Andrea and Tricia come from entirely different backgrounds and approach the question of training and communications from two entirely different — but complementary — perspectives. Andrea is a compliance professional who has been in the legal and compliance space for upwards of 23 years, focusing solely on compliance for the last 14 of them (yee-ikes!). Tricia has spent the better part of her career not only writing but persuading others with her writing — in the advertising and social media arenas. And both of us are firm in our conviction that training is not communications and communications are not training.