The Man From FCPA must admit, he had never considered purchasing an airplane ticket was a way to get arrested, but it looks like that is where United Airlines is about to take that part of its "fly the friendly skies" customer experience. For those who might not have heard, United demanded four passengers disembark a flight because the airline allegedly had oversold the flight. It came to down to one passenger, who refused to leave and was physically hauled off the flight by security guards. This horrific scene was caught on videotape for all the world to see.

United tried to claim the flight was oversold. It turned out, however, that United simply wanted to fly four of its employees, on non-paying tickets, to another location, so they physically hauled off a paying passenger who had been ticketed and seated. As any airline passenger who has ever listened to the safety talk before a plane departs, it always ends with the notation that it is a federal law to obey the flight attendants. Was the man arrested? That is an intriguing question as United referred all inquiries to “appropriate authorities.”

Less than two weeks after refusing to allow a 10-year girl to board a flight wearing leggings, now United is forcibly throwing passengers off flights to fix a United scheduling error. This is the same airline, whose former CEO resigned after he approved a bribe to the then-head of the New York and New Jersey Port Authority. It is pretty clear there is a huge cultural problem at the company. At some point, when passengers are made subject to arrest for simply buying the company’s product, the company might realize it is in the middle of a self-induced PR nightmare.

The U.S. Justice Department has made clear that any compliance program starts with the top of the organization and the tone it sets for doing business ethically. Yet, United’s tone seems to be how poorly it can treat its customers. When you become subject to arrest and physical ejection from an airplane for simply following the rules, it becomes difficult to see a sustainable business model.