In an article in the July/August edition of the ACC Docket entitled “Rethinking the Annual Compliance and Ethics Flea Dip”, author James Nortz discusses the annual compliance and ethics training program that most US company’s employees receive which he calls a ‘flea dip’. While he believes that such annual training is well-intentioned, he states that it is “a bit implausible that these annual pilgrimages” would have their intended effect of raising overall employee aware of their company’s Code of Conduct and thereby reducing overall enterprise compliance risks.