In 2015, I undertook an extensive literature review and interviewed 23 anticorruption experts and practitioners to explore a simple question: What does organizational culture look like in a corrupt company? My work was a direct challenge to the long-dominant “bad apple” or “rogue employee” explanation of corporate wrongdoing, focusing instead on the organizational and team conditions that undermine integrity. Subsequent corporate scandals—for example, regarding fake accounts at Wells Fargo or car emissions at Volkswagen—have illustrated the importance of overall culture, rather than individual traits, in driving or undermining integrity. Regulatory interest in the importance of organizational culture has increased. This post will explore the implications of my research study for regulators who seek to evaluate compliance programs. Continue reading