From Mindhunter to Risk Hunter: Profiling for Compliance Professionals
Time to Think Like a Criminal Profiler?
One of my first managers specialised in analysing terrorist groups in North Africa and the Sahel. He had an uncanny ability to identify the perpetrators behind attacks before anyone else. His explanation was deceptively simple: “Target + modus operandi = who.” It’s a variation of the famous FBI profiler John Douglas (of Mindhunter fame) model: “How + why = who.”
These frameworks—used by investigators, intelligence analysts, and risk professionals—are built on understanding patterns, motivations, and behaviours. Can those of us tasked with predicting, preventing, or responding to misconduct, ethical missteps, and risk hack these frameworks?
Common Mistakes If you’re managing integrity risks like corruption, fraud, sanctions violations, or human rights abuses, you’ve probably heard of frameworks like Cressey’s Fraud Triangle (pressure, opportunity, rationalisation) or police concepts like means, motive, and opportunity. These are helpful frameworks, but there’s a dearth of information on how to apply them.
Too often, we focus on individual pieces of misconduct without connecting the dots. By failing to analyse patterns across incidents or understand the deeper motivations behind unethical behaviour, we leave ourselves vulnerable to repeated risks.
A Better Way? Think like a profiler! Criminal profilers don’t just look at isolated actions—they analyse patterns over time. They ask questions like:
- Why does this behaviour keep happening?
- What pressures might drive someone to act unethically?
- How do past incidents predict future misconduct?
For risk professionals, this could include:
- Motive/Pressure/Why: History repeats itself, especially the “pressures” bit (at their most basic: fear or greed). The most common one for us is aggressive targets + challenging economic conditions = fraud.
- Modus Operandi/How: Patterns matter. If misconduct relies on specific tactics (e.g., falsifying invoices), these methods will likely surface again under similar conditions.
By understanding the “how” and “why” behind unethical behaviour, we can better anticipate risks before they escalate.
Tactical Application
- Analyze Patterns: Look beyond individual incidents—what trends emerge across divisions or geographies?
- Understand Motivations: Consider pressures driving behaviour (e.g., financial targets or cultural norms). Empathy is key here; imagine yourself in the shoes of stakeholders under stress.
- Connect Risks: Build profiles for recurring issues (e.g., fraud schemes) and map how they intersect with other risks (e.g., corruption or human rights violations).
Top Tip Start small: focus on high-impact or high-likelihood (recurring) risks where patterns are already visible (e.g., repeated facilitation payment requests in certain regions). Gradually expand your analysis as you uncover connections.
Earlier this week, I spoke to someone familiar with mining sector risks. They’re now working for an investor, and one of their proposed deals involves a renewable energy supplier (selling to industry, not the grid, including mining). When I was able to demonstrate some of the most common integrity challenges at the intersection of those two industries (based on profiling in work in other markets), they opened up. Any investigator will tell you that people often want to talk. They want to open up, even about the bad stuff. If we can have a few anticipatory examples up our sleeves (as a profiler does to demonstrate understanding and connection), we become partners - predicting, protecting, and preventing recurrence.
If you’re having trouble understanding how this could be relevant to your work, let’s talk!
Saying No, Again (not a no-no)
People seem to relate to the “ways to say no” content. All you overworked, diligent, and above-and-beyond types can’t help it!
Last week, I read a newsletter from the NSFW author of The Subtle Art of Not Giving a F**k, Mark Manson.
Rather than paraphrase, I pass this on, as it’s funny and helpful. I constantly have to tinker with my triage frameworks and practice of the art of saying no (or at least, not now). Here’s what Mark wrote:
“Say “no” to one thing or person that’s not good for you. If you don’t know how here are a few ideas:
- “Thanks, but that doesn’t work for me…”
- “I appreciate X about what you’re saying, but I can’t get on board because of Y…”
- “I have a rule: if it’s not a fck yes then it’s a no. And this isn’t a fck yes for me.”
- “My new year’s resolution in 2025 is that I don’t say ‘yes’ to anything that could potentially cause me to want to claw my own eyes out, so… no.”
- “I’d rather drink bleach and bake a cake made out of dog sht than do that… so, abso-fcking-lutely not.”
Let me know what the thing was you said “no” to, and how much better you feel now that’s no longer in your life.“
Please, please tell me if any of you use options 4 or 5!