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Breaking Bad taught me . . . compliance

Compliance officers looking to increase ethical behavior in their companies might consider putting aside traditional training methods and instead administer hits of dopamine or distribute food pellets as rewards for doing “the right thing.”

Something beyond the ordinary is needed: the frisson of cheating creates a happiness that is practically addictive according to a report in the New York Times. Call it the Walter White effect.

“I liked it,” said Walter, the meth-making former chemistry teacher said in the widely watched finale to the television series Breaking Bad. “I was good at it. And I was really…I was alive.”

The Times-reported research shows that cheaters get an emotional bump that can help reinforce bad behavior and provide incentive for repeating that behavior. The findings are part of a growing body of behavioral research that have very practical implications for constructing and running compliance programs.

For instance, how does a compliance officer overcome the physiological attractiveness of breaking bad with programs that are usually based on ethics (doing the “right thing”) and rationality (avoiding prosecution)? Broccoli seldom wins out over chocolate.

Compliance solutions that measurably change behavior may be of more practical use than training efforts appealing to morality or ethics.

When research shows you can increase the truthfulness of information reported in forms by requiring the signature at the beginning of the document rather than providing an attestation at the end, you have a quick and easy method for potentially improving reporting compliance.  

Research suggests that a feeling of anonymity can significantly increase the likelihood of cheating in many situations. Software programs that create routine contacts with your third-party service providers and make them partners in your compliance efforts can help discourage cheating simply by reducing that anonymity.

This is not theoretical stuff. Compliance officers can draw on a growing body of research on the complex behaviors involved in cheating, including research on topics as diverse as whistleblower behavior and the effect of hand-washing in making one feel better after having done something unethical.

While removing wash basins from executive lounges may not be an option, behavioral research has the potential to greatly influence the contour of compliance efforts in the future.


Russell Stamets is a Contributing Editor of the FCPA Blog. He was the first non-Indian general counsel of a publicly traded Indian company and was general counsel for a satellite broadcasting joint venture of a large Indian business house. He can be contacted here.

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