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Harry Cassin
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How ‘groupthink’ can wreck an effective compliance program

In February 2012, a group of 16 skiers highly trained in avalanche safety defied clear avalanche warnings. They sought the deep, untracked powder along Cowboy Ridge, about 75 miles east of Seattle, outside approved boundaries. When the avalanche struck, it killed three of them. Despite the credible warnings, despite all the skiers’ advanced training in avalanche safety, no one in the group spoke up about the deadly risks.

A member of the group who survived, Megan Michelson, later asked, “[A]ll of us had been trained to recognize these risk factors, yet we did not heed them. Why?”

A decade before the incident, Michelson said, there was a big push for avalanche education and certification, which everyone in the group received. Instead of increasing safety, the widespread avalanche safety campaign and training somehow eroded safety by creating a false sense of confidence.

Michelson said the skiers had all been taught to use pre-set safety checklists to assess avalanche dangers. But the group abandoned checklists; instead, everyone put confidence in their collective skills, experience, education, and knowledge of the terrain.

She concluded that “human factors – familiarity, social pressures, and the expert halo (in which the experienced believe that their expertise will keep them safe) – were more to blame than previously thought.”

Psychologists have a name for what happened. It’s called groupthink. And it’s a lurking danger that can impair the judgment of any group, including employees trained to deal with compliance.

Groupthink is counter intuitive. It collides with proverbs we all know and trust: There’s safety in numbers, wisdom in crowds, and two heads are better than one. Groupthink turns that conventional thinking on its head.

Psychology Today says groupthink occurs “when a group of well-intentioned people makes irrational or non-optimal decisions spurred by the urge to conform.” It creates a tendency for individuals “to refrain from expressing doubts and judgments or disagreeing with the consensus . . . members may also ignore ethical or moral consequences.”

Most of us associate the bad effects of groupthink with institutions, like run-amok military units or rogue ruling parties, and not with smaller groups like the 16 skiers who ignored the avalanche warnings. But the skiers’ tragedy shows just how dangerous groupthink can be to any group, even small groups inside companies that face compliance decisions.

So, how do we protect against groupthink among employees?

Compliance trainers should stress that individuals remain accountable even while working on a team. Everyone should speak up when they know or suspect from their training or intuition that something’s wrong.

In training, use examples, role playing, scenarios, and repetition to teach employees to rely not on experience or groupthink-influenced ideas, but on real factors like “avalanche warnings.”

Teach employees to recognize and avoid human factors that impede rational decision-making in times of stress. Keep in mind the “human factors” skier Megan Michelson said contributed to groupthink: Familiarity, social pressures, and the expert halo, which erroneously convinced the skiers that their collective training would keep them safe.

Finally, but fundamentally, make sure employees are clear about the boundaries of safe business practices. The FCPA Blog has benchmarked anti-bribery policies of over fifteen companies. Policies range from a single page to over 30 pages. Compliance trainers need to translate their company’s policy into clear guidance about the safe boundaries in which employees — individually and in groups – must operate. The objective is to condition employees, so that warning bells sound in their heads when they get too close to those boundaries.


It’s natural for most of us, in our different ways, to seek the thrill of deep, untracked powder. At work, that may happen in connection with a potential new customer, or foreign sales territory, or even a more efficient business method. But whenever temptations to operate outside the boundaries come along, that’s when groupthink can strike.

There are numerous training opportunities and certifications in the compliance industry today, and that’s all good. One step further, though, is to ensure that compliance training helps employees avoid groupthink by sticking to their pre-set “checklists” at all times.

Compliance risks, like the danger of avalanches, eventually confront even the most seasoned, trained, and credentialed groups. When that happens, how individuals in those groups respond will depend in large part on the training they’ve received, believed, and internalized.

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