Developing and maintaining a strong culture of compliance is not easy. While behavioral studies and compliance surveys identify managerial modeling and procedural fairness as two key drivers, and DOJ emphasizes both issues, they take work and a considered approach. Measuring comfort levels in reporting can provide insights into the compliance culture, but that also poses challenges, as establishing reliable data gathering processes and pursuing a granular analysis requires substantial attention. Nonetheless, the relevance of these activities to compliance programs, and to DOJ, makes the effort worthwhile. In a two-part guest article series, Paul Hastings partners Jon Drimmer, Matt Herrington and Tom Best examine the latest behavioral ethics research and provide practical steps a company can take to ensure that its program is hitting the right marks. See the Anti-Corruption Report’s three-part series on behavioral-science lessons from the Wells Fargo scandal: “Culture Eats Compliance for Lunch” (Nov. 28, 2018); “Devil in the Decentralization” (Dec. 12, 2018); and “Focusing on the ‘Regular Apples” (Feb. 6, 2019).