BOOK REVIEW: Corporate Scandals: Diagnosing the “Dark Pattern” in Modern Organizations
- Tomasz Kruk
- Oct 11
- 3 min read

What if the seeds of a corporate scandal aren’t born in bad apples — but in the fertile soil of unchecked culture?
That’s the core argument in The Dark Pattern: The Hidden Dynamics of Corporate Scandals by Guido Palazzo and Ulrich Hoffrage — a bold and, at times, unsettling examination of how ordinary organizations slide into extraordinary ethical failure.
To those of us in compliance, the book reads less like theory and more like diagnosis.
Scandals Don't Start with Crime — They Start with Culture
Palazzo and Hoffrage introduce a framework they call the “dark pattern” — a web of organizational failures that create ethical blindness. This isn’t about one bad executive or a single lapse in judgment. It’s about how the system quietly corrodes itself from within.
Their nine “building blocks” of the dark pattern are:
Rigid Ideology
Toxic Leadership
Manipulative Language
Corrupting Goals
Destructive Incentives
Ambiguous Rules
Perceived Unfairness
Dangerous Groups
Slippery Slope
For any compliance officer, this reads like a risk assessment primer. These elements mirror what we've seen — and often tried to prevent.
The takeaway? Ethics doesn’t erode in a single moment. It fades, quietly and collectively, unless someone stops it.
Why Don't They Stop? Because No One Makes Them
The authors underscore a powerful truth: most wrongdoers don’t stop because they “see the light.” They stop because someone — or something — forces them to.
“Only later, when they have been made aware of it, do they wake up… They ask themselves: How could I have acted like that, and why didn’t I see it at the time?”
Palazzo draws parallels to historical atrocities, including the German Third Reich. At one point, he describes Enron’s Jeff Skilling and Andrew Fastow as “knights and willing executioners of neoliberalism.” It's a provocative — perhaps too provocative — comparison.
The book references scandals involving Wells Fargo, Enron, Purdue Pharma, Theranos, Lehman Brothers, Arthur Andersen, Boeing, Volkswagen, and Ford. And it reflects on individuals from Joseph Schumpeter and Milton Friedman to Immanuel Kant, Dante Alighieri, Hannah Arendt, Lance Armstrong and Adolf Eichmann — connecting moral philosophy, war crimes and economic ideology with corporate behavior.
Personally, I would not equate corporate fraud with war crimes. But I understand the point: unchecked ideologies, especially when wrapped in profit-driven incentives, can escalate into harm — even evil — if left unchallenged.
How Compliance Programs Counteract the Dark Pattern
This is where the book becomes practically valuable for compliance professionals. Because for each “dark pattern” risk, there’s a corresponding control — if we’re smart enough to apply it.
Here’s how a comprehensive 9-element compliance program (based on DOJ, US Sentencing Guidelines) directly neutralizes the nine dark patterns:
Compliance vs. Dark Pattern Risks
Compliance Program Element | Purpose | Dark Pattern Risks Countered |
1. Leadership & Commitment | Set culture of integrity, accountability, and tone at the top. | Rigid Ideology · Toxic Leadership |
2. Risk Assessment | Identify and prioritize risks by geography, sector, and operations. | Corrupting Goals · Slippery Slope |
3. Policies, Procedures & Documentation | Provide clear, accessible rules; ensure consistent documentation and transparency. | Manipulative Language · Ambiguous Rules · Perceived Unfairness |
4. Training & Communication | Equip employees with practical knowledge to act ethically. | Rigid Ideology · Manipulative Language |
5. Oversight & Resources | Ensure compliance is independent, resourced, and empowered. | Toxic Leadership · Dangerous Groups |
6. Incentives & Discipline | Align rewards/penalties with ethical behavior. | Corrupting Goals · Destructive Incentives · Perceived Unfairness |
7. Reporting, Investigation & Response | Provide safe, confidential channels; ensure timely, fair investigations. | Toxic Leadership · Dangerous Groups · Perceived Unfairness |
8. Third-Party Management | Control risks in agents, distributors, contractors, and partners. | Destructive Incentives · Ambiguous Rules |
9. Controls, Monitoring & Improvement | Detect and prevent misconduct; audit, learn, and adapt. | Slippery Slope · Destructive Incentives · Rigid Ideology |
Key Insight:This 9-element framework keeps compliance robust yet practical. The ninth element — controls & improvement — is essential. It creates a feedback loop: what you monitor → what you learn → how you adapt. Without this loop, organizations fall prey to the very "slippery slope" the book warns against.
Final Verdict: Provocative — and Useful

Would I recommend The Dark Pattern? Absolutely.Would I agree with all of its comparisons? No.But that's not the point.
This book forces us to look beyond individual bad actors and see the broader system that allows — or even encourages — ethical decay. It gives us a language and lens to challenge complacency.
And as compliance leaders, we must ask ourselves:
Is our program preventing dark patterns — or quietly enabling them?




Comments