CX, Virtue Ethics, and Dark Patterns: Lessons from Amazon’s $2.5 Billion FTC Settlement

Dark patterns expose deeper ethical issues in customer experience. Here’s how virtue ethics grounds fair decisions that build customer trust.

When you’ve struggled to cancel a subscription, waited on hold for what feels like forever, or battled confusing website flows, what does that friction say about a company’s and its leaders’ attitudes and ethical principles toward its customers?

Amazon as a Catalyst for a Conversation on CX Ethics

Recently, Amazon agreed to pay a $2.5 billion settlement over its Prime subscription flows. If you were a customer, signing up for Prime was effortless. Cancelling required navigating a four-page, six-click, fifteen-option process. This was a violation of law, according to the U.S. Federal Trade Commission (FTC).

Such design tricks are known as dark patterns, manipulative design choices that trap, trick, or confuse customers into making choices they might not otherwise make, usually so a company can make or retain revenue.

Like sludge, which I have written and spoken about before, dark patterns make tasks harder for people. While Amazon admitted no wrongdoing, an FTC spokesperson said Amazon knew it would likely lose in court, prompting the historic, pro-customer settlement.

Why The Amazon Case Invites a Discussion on Customer Experience Ethics

When customers encounter an experience that confuses, traps, or exhausts people, it’s not just poor UX design. It’s a moral decision on the part of people responsible for the company’s performance and culture. Decisions have been made along the way that neglected the question: What kind of organization do we want to be?

Building a Customer Experience Ethics Vocabulary

But ethics has never been a prominent part of CX leadership development, so the profession has been missing a vocabulary for what’s at stake when friction is purposefully built into a customer’s day. That is fairness, justice, consent, and virtue. But this can be easily changed.

Virtue Ethics for Customer Experience Leaders

Virtue ethics, an Aristotelian-era way of thinking, offers a timeless lens for CX decision-making on the part of an individual in contribution to an overall culture.

Five Core Elements of Virtue Ethics

1. Character over compliance. Focus on what you’re becoming, not just whether you’re following the rules. If making money is the goal, pause and reflect, “How are we going to reach this goal?” Strive to do the right thing for the right reasons.

2. Moral habits. Ethics grow from daily habits of fairness. Not just a one-time decision and you move on. When you see others showing virtue, as a leader, you reinforce it, because not everyone is born with an understanding of virtue.

3. Practical wisdom. Decisions at work aren’t always black and white; virtue ethics calls for balancing competing values like fairness, care, and honesty. It’s about doing what’s good as well as what works.

4. Right motive. Intent matters as much as outcomes. A big challenge, as dark patterns show us, is that what’s good for a company or its shareholders isn’t necessarily what is best for customers.

5. Human flourishing. True success means helping people thrive. In business, that means designing experiences that don’t exploit people. You make the right choice, even if it means you might not receive external recognition.

Most organizational leaders don’t necessarily set out to deceive. But their actions and values do play a significant role in setting the ethical climate of an organization—the context employees find themselves operating within every day.

Dark patterns often grow out of metrics and incentives left unexamined. Virtue ethics provides a lens for seeing where performance goals quietly cross into manipulation. There is a trust-building opportunity in building systems that achieve success without compromising integrity.

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