Compliance training and e-learning have become inseparable at Credit Suisse.
We follow the financial services company’s learning audit trail
Compliance training is one of today’s big challenges for training managers.
But it has also given e-learning one of its greatest opportunities to shine.
Nowhere is this more true than in financial services, where e-learning has made
the difference between whether global brands meet their compliance training
Credit Suisse Group, which has its headquarters in Zurich, is one of the
world’s leading financial services companies, with 50,000 staff working in 50
countries. As such a global institution, it must observe a complex set of legal
and compliance regulations.
The Swiss Federal Banking Commission (SFBC) has been increasing the amount
of regulatory control and monitoring of the Swiss financial environment with
anti-money laundering and client data protection forming two key areas of
focus. In foreign locations, Credit Suisse Financial Services maintains compliance
with Swiss regulations, in addition to the policies of any regional regulatory
authorities. Sited at every significant Credit Suisse location is a legal unit
with a legal and compliance officer, and the reporting requirements of that
officer can differ according to the local regulatory authority.
"Credit Suisse is committed to ensuring compliance with the regulatory
obligations in every location in which it operates," says Anthony
Cerquone, head of talent development and leadership technology at Credit Suisse
"Like all large financial institutions, this imposes an enormous
training obligation which would be almost impossible to meet with traditional
To meet such a demand, Credit Suisse has put a robust e-learning
infrastructure in place. It comes as a result of a three-year relationship with
Dublin-based e-learning technology provider WBT Systems and its Swiss partner
Tertia Edusoft. It began with a pilot for 20 people and following this, WBT
implemented its TopClass e-learning suite for Credit Suisse Private Banking to
deliver online training to 8,500 staff.
Now it is being used to deploy legal and compliance training to 50,000
employees, and sales training to the group’s 4,000-strong sales team.
"Over the past three years we have enjoyed a very productive
relationship with WBT," says Cerquone. "We chose WBT because of its
understanding of our business. The commercial, competitive and regulatory
environment that we play in is very complex. WBT understands this and is
helping us respond to these challenges and to establish a robust audit-ready
regulatory compliance training system."
As an aside to the e-learning implementation, WBT is also utilising its
compliance audit tool. CIARA (Compliance Infrastructure Audit Readiness
Assessment) is designed to give the CEO, board and compliance officers a view
of the organisation’s readiness to comply with relevant regulatory legislation,
and successfully handle a regulatory audit. It comprises an in-depth survey of
more than 100 questions, one-to-ones and presentations, and is based on many
years of experience in the financial services sector.
The initial pilot played a major part in not only testing the concept of e-learning
but also in helping to make a business case for it. As a follow-up to the
pilot, which featured the use of TopClass, the 20 participants were interviewed
about what they thought of the training. The feedback was so positive, it was
used in the proposal to the board, and as a result the e-learning initiative
was brought forward by two months.
The web-based TopClass suite integrates with Credit Suisse’s HR portal and
allows the company to create, deploy and manage learning across the
organisation. The system has two million users worldwide and customers include
Dow Chemical, US Department of Defense, Smith and Nephew and Volvo CE. It
includes a learning management system (LMS) and a Learning Content Management
System (LCMS), both of which are utilised extensively by Credit Suisse.
"The LMS module allows it to create a portal for all training – online,
face-to-face and blended – and users can select courses through the catalogue,
through a skills gap analysis or automatic assignment based on their job or
organisational group membership," explains Des Noctor, vice-president of
sales and services at WBT Systems.
The system also caters for Credit Suisse’s band of mobile sales workforces
(via TopClass Mobile), allowing staff on the road to study a course offline on
"They can then synchronise data back to their training record when they
next have a connection," says Noctor. And not only can it facilitate the
e-learning, but the LMS is also a valuable measuring tool for compliance
"It lets you do things cheaper, faster and better, but because it
records and tracks what you do, it also lets you demonstrate your compliance
training to the regulatory bodies," he says.
Much of the online content behind the LMS is developed by Tertia Edusoft,
and Credit Suisse itself uses the TopClass Publisher content assembly and
authoring module to create content internally. The courses also include IT
training and soft skills as well as Credit Suisse’s own product training.
One of WBT’s biggest challenges was presented by the volume and time factors
involved in the project, epitomised by Credit Suisse’s home-grown device for
testing itself exhaustively in-house on compliance issues.
"We and our colleagues in legal and compliance have developed ‘Case of
the Month’- a scenario-based approach to testing staff on work situations that
require an understanding of compliance," says Cerquone.
The course is mandatory for several thousand staff and is available to
everyone else in the organisation. It is simply presented via on-screen
questions in compliance-related areas. "The compliance department must
have absolute confidence in the reliability of TopClass as a delivery
vehicle," says Noctor. "A different one is rolled out every month,
and this demonstrates how Credit Suisse seeks to go above and beyond to audit
Credit Suisse is justified in putting such measures in place to audit itself
so rigorously – the cost of non-compliance for organisations in the financial
services sector is considerable.
As well as the obvious financial consequences, the potential damage to an
organisation’s brand is also of major concern. In a White Paper written by WBT
(see download details in box below, left), research conducted with compliance
officers working within financial services providers in the UK found that
damage to the brand and reputation was the overwhelming concern of 89 per cent
of respondents. Second was the ability to carry on conducting business
following a compliance failure, and financial penalties incurred.
"Customer retention and loyalty is driven largely by the level of trust
placed by customers in a bank, insurance company or brokerage," writes
Duncan Kelly, WBT founder and chief technology officer.
"Frequently this trust is implicit and only considered in the light of
the negative publicity of a compliance failure."
Three key criteria for e-learning
Comprehensive: Provide broad functionality to grow with your
needs from an initial departmental or tactical solution to enterprise-wide
service. Such a solution should provide capabilities in the areas of content
management, learning management and performance management.
Scalable: In both technical,
performance terms and in terms of process support, the solution must have
proven itself to be effective in large-scale distributed enterprise
Flexible: The system must be able to
grow with your changing needs, many of which will be largely unknown today.
This must include the ability to tailor the solution such as support for
modifying the user interface and language support based on your organisational
needs. Support is crucial for a variety of content types and sources, allowing
you to leverage capabilities of your subject matter experts to capture
knowledge directly as well as leverage the significant investments you have
made and will continue to make in learning materials for both the classroom and
Systems White Paper e-Learning and Financial Services which can be downloaded
for free at www.wbtsystems.com. (the site does request that you to register
before you are able to download).
In summary: Credit Suisse
Credit Suisse’s aim: To deliver online learning to 8,500 staff,
followed by legal and compliance training to 50,000 staff and sales training to
4,000 sales staff.
Why? Legal and compliance training
places a huge burden on training departments and without e-learning it is
doubtful that firms could fulfil the obligation.
Is e-learning delivering? At the time
of writing the system was due to go live, but the pilot project was judged such
a success the e-learning initiative was advanced by two months. Individuals who
participated in the pilot were interviewed and the feedback received was so
positive it was used as part of the business case for e-learning when presented
to the board.