More on AI Agents Taking Employee Training

Today I want to continue pulling on the thread we first uncovered last week, that ChatGPT’s latest artificial intelligence system is so advanced that employees can have it take their ethics and compliance training for them. We still have lots of implications both short- and long-term that compliance officers need to consider. 

For those who missed our previous post on the subject, compliance training vendor Ethena published an article demonstrating how ChatGPT’s latest model includes an “agent mode” that employees can use so that the AI agent takes their compliance training courses for them. Just turn on agent mode, give the agent the URL of your training course, and tell it to take the course for you. The agent will then watch or read whatever training material the course contains, answer questions about the material, and submit those answers on the employee’s behalf. The CCO or HR department would be none the wiser.

This is unsettling stuff. The prospect of employees using AI as a short-cut for compliance training (or any company training at all, really) raises a host of questions that compliance officers need to address — everything from immediate steps you should take to prevent AI-driven cheating; to long-term reforms corporations will need to embrace that will change the very nature of what training is. 

Short-Term Training Issues

First, compliance officers need to develop a policy and internal control response to be sure that if employees start using AI to take their training for them, you can keep pace with those risks.

For example, do you have a policy that expressly requires employees to take all training themselves, without the assistance of artificial intelligence? Does the training module include some sort of declaration where employees certify that they aren’t using AI? 

Those policies and certifications won’t necessarily stop employees from using AI as a short-cut for training, but at least they’ll give you the legal cover to discipline offenders when you find them. 

That brings us to our second point: You’ll need to monitor employee training data to see whether improper AI usage might be afoot. Ethena mentioned a few warning signs you could track, such as: 

• A sudden increase in training completion rates;
• Different employees taking the same amount of time to complete a training course;
• A spike in the percentage of correct answers given;
• Different employees suddenly submitting answers that are uncannily similar.

Any of those trends might be clues that employees are using AI to take their training. Then you could work with the IT or internal audit teams to conduct a more forensic investigation into whether that’s actually the case. 

You could also compare training completion data against employee behaviors, which is something you should already do anyway. For example, if employees start acing their training courses, but you still see the same volume of control failures or misconduct allegations (documented through internal audits or hotline reporting analysis or some other mechanism), that would suggest that whatever your employees are doing with their training, they aren’t learning from it.  

All the above, however, are just stop-gap measures to help you prevent the abuse of AI in employee training. We still need to consider deeper issues about how AI will change the nature of what employee training is and how it’s delivered. 

The Longer Horizon

Once compliance officers have those immediate responses in place to help you understand the severity of this threat — which, let’s be clear, may not be all that severe; but at least you’ll know — you can move onto the next logical question. 

Why would employees even bother to use AI to complete their training in the first place? Like, what does that say about the people you hire and the corporate culture they inhabit? 

That point came up a lot as I asked compliance officers what they thought of all this. Nobody really disputed that employees could use AI in this manner, but many were skeptical that their own company’s employees actually would go down this route. After all, this crowd said, compliance training isn’t that burdensome.

Let’s consider a few points here. First, even if your compliance training isn’t that hard, ChatGPT (and other AI agents sure to follow) will make delegating that training to AI even easier. Soon enough, people will simply be able to say, verbally, “Please take my compliance training for me. Here’s the URL.” So the more important point to contemplate is why an employee would delegate training to an AI agent in the first place. 

Well, an employee would delegate training to AI when he or she sees no benefit in taking it — when taking said training is seen as a burden to be off-loaded rather than an opportunity to learn. 

That’s a matter of corporate culture. If employees view training in that way, the compliance officer and everyone else involved in training (HR, your training vendors, the tech teams helping with integration, and the like) need to gather together and figure out how to remedy that situation.

Maybe the material isn’t engaging. For example, maybe you deliver it in a day-long marathon of employees staring at a single computer screen; rather than in smaller bursts over weeks or months, in a mix of computer courses and in-person training. 

Or maybe your culture is flawed. Maybe the workforce sees compliance training as a must-do obligation, rather than a chance for employees to help the company reach a higher state of performance. In that case, senior management might need to emphasize the importance of an ethical culture through executive messaging (and then back up those words with more budget for you and your vendors to revise training as necessary). 

One excellent comment came from Jonathan Marks, a long-time friend and thinker on corporate misconduct issues:

What this underscores for me is that compliance and ethics programs are only as effective as the integrity of the people participating in them. Technology will always evolve faster than controls, which is why we cannot rely on training as a check-the-box exercise. In my experience, effective compliance training is not about passing quizzes or clicking through modules — it is about engaging employees in a way that changes behavior and strengthens culture.

I agree completely.