U.S. companies tend to favor compliance-based ethics programs, while Europe’s are more ethics-based. Outside the United States, compliance-based systems have been criticized as excessively mechanistic and rule-based. Critics in favor of ethics-based approaches that articulate broad principles see compliance-based approaches as narrow “box-ticking” for acceptable behavior. The experience in the United States with what started as a pure compliance regime may be leading to the development of a third way in which companies are encouraged to use strong compliance structures in the service of broader ethical mandates.