Financial Misconduct
Predatory financial practices that harm consumers, investors, or beneficiaries — deceptive fee structures, insurance claim denials, investor fraud, market manipulation, and financial products designed to extract value from unsophisticated counterparties. Distinct from corruption (which covers bribery/fraud against governments), predatory_lending (which specifically covers credit products), and anticompetitive (which covers market structure violations).
Excluded Companies (154 total)
Showing 25 of 154 companies excluded under this screen.
| Ticker | Company | Reason |
|---|---|---|
| JPM | JPMorgan Chase | JPMorgan Chase has accumulated more than $40 billion in fines and settlements since 2000, according to ViolationTracker, across 284 enforcement records spanning securities fraud, market manipulation, money laundering failures, and consumer abuses. The bank's $13 billion settlement with the Department of Justice in 2013 over fraudulent mortgage-backed securities — including those originated by Bear Stearns and Washington Mutual — was at the time the largest civil settlement with a single entity in American history. In 2020, the CFTC imposed a $920 million penalty, the largest in the agency's history, after JPMorgan traders in New York, London, and Singapore spent nearly a decade spoofing hundreds of thousands of orders in precious metals and U.S. Treasury markets. The bank paid more than $2 billion in penalties for Bank Secrecy Act violations tied to its failure to report suspicious activity flowing through accounts held by Bernard Madoff, whose Ponzi scheme ran undetected for decades. The London Whale debacle cost the bank over $6 billion in trading losses and $920 million in regulatory fines after a single derivatives desk in London accumulated outsized, concealed positions. In 2023, JPMorgan agreed to pay $290 million to survivors of Jeffrey Epstein's sexual abuse and a further $75 million to the U.S. Virgin Islands, resolving claims that the bank maintained Epstein's accounts despite years of internal red flags about the source and nature of his transactions. The Federal Reserve fined the bank $98.2 million in 2024 for inadequate surveillance of trading activity across its own desks and client accounts. The pattern is not a handful of isolated incidents but a recurring institutional posture: violations spanning spoofing, mortgage fraud, sanctions evasion, consumer fee abuses, and failures of anti-money-laundering controls, with new enforcement actions arriving almost every year. |
| PRI | Primerica | Primerica operates a multi-level marketing (MLM) structure for selling term life insurance and financial products, a business model the company describes as "affiliate marketing." Independent agents earn commissions on products they sell and also receive overrides on sales made by agents they recruit. In April 2024, an independent short-seller report published by The Bear Cave described Primerica as "a pyramid scheme," citing extensive regulatory and legal records. The report alleged that the vast majority of recruited representatives earn little to no income, while the economic model is sustained by recruiting new participants. The company has been the subject of regulatory action concerning its sales practices. In a 2022 New York State court decision (*M.Z. v Ortiz*), a Primerica agent and the corporate entities Primerica Financial Services Agency of New York, Inc. and Primerica Life Insurance Company were named as defendants in a lawsuit alleging violations of New York's Executive Law concerning discriminatory practices. Furthermore, the Mutual Fund Dealers Association (MFDA) in Canada has entered into a settlement agreement with a Primerica-affiliated representative for undisclosed misconduct, noting the agreement saved the MFDA the time and resources of a full hearing. While Primerica disputes characterizations of its model as predatory, the combination of its MLM compensation structure, regulatory settlements, and ongoing litigation over sales practices aligns with the category of financial products and distribution models designed to extract value from unsophisticated participants. |
| UNH | UNITEDHEALTH GROUP INC | UnitedHealth Group has accumulated $2.7 billion in total penalties across 449 violation records since 2000, according to ViolationTracker. The company faces an overlapping set of federal and state enforcement actions reflecting systemic issues across its insurance, data, and services businesses. In December 2022, OptumInsight paid $15 million to settle allegations of accepting kickbacks from a laboratory company in violation of the Anti-Kickback Statute. In 2024, the DOJ intervened in two separate False Claims Act lawsuits alleging UnitedHealth knowingly inflated Medicare Advantage risk adjustment payments — the DOJ estimates the government paid UHG more than $7.2 billion from 2009 through 2016 based on diagnosis upcoding. In July 2025, UnitedHealth disclosed it was cooperating with DOJ criminal and civil investigations into its Medicare billing practices. Separately, The Guardian documented that UnitedHealth allegedly paid bonuses to nursing homes to reduce hospital transfers of Medicare Advantage patients, saving UHG millions while risking patient safety. North Carolina fined UnitedHealthcare $3.4 million for balance billing violations, and Minnesota imposed a $450,000 fine for mental health parity failures. In a landmark case, UHC paid $15.6 million for violating the Mental Health Parity and Addiction Equity Act — the first DOL enforcement of the parity law against a health insurer. The pattern spans Medicare fraud, kickbacks, mental health parity violations, and systematic claims denial. |
| ECPG | Encore Capital Group Inc | Encore Capital Group operates one of the world’s largest debt collection and debt purchasing businesses, buying portfolios of defaulted consumer debt for pennies on the dollar and then pursuing collection. Its primary business model involves extracting payments from consumers on debts that are often old, disputed, or unverified. The Consumer Financial Protection Bureau (CFPB) has taken repeated enforcement action against the company for deceptive collection tactics. In 2015, the CFPB issued a consent order requiring Encore and its subsidiaries to reform their practices. In 2020, the CFPB filed a lawsuit alleging the company failed to implement those required reforms, leading to a new settlement. In 2023, the CFPB again took action against Encore Capital Group for using deceptive tactics to collect bad debts. This pattern of regulatory action indicates systemic issues with compliance and consumer harm. In February 2025, an Insolvency Service investigation in the UK resulted in the shutdown of an Encore subsidiary for failing to hand over money it had collected. This conduct has also drawn scrutiny from investors. In March 2025, a law firm announced a securities fraud investigation into Encore Capital Group on behalf of investors, following a significant stock price decline. A separate class action lawsuit alleges the company misled consumers. The company’s own regulatory filings acknowledge litigation and enforcement as a persistent key risk to its global debt recovery business. |
| DNKEY | Danske Bank | Danske Bank has engaged in a multi-year pattern of financial misconduct spanning market manipulation, investor fraud, and systemic anti-money laundering failures, resulting in over $2 billion in fines and forfeitures. In December 2022, the bank pleaded guilty in U.S. federal court to conspiring to commit bank fraud, forfeiting over $2 billion for its role in a $200 billion money laundering scandal originating from its Estonian branch. The U.S. Securities and Exchange Commission simultaneously charged Danske Bank with fraud for misleading investors about its deficient anti-money laundering controls. This misconduct extends to market manipulation. In January 2025, the Norwegian Financial Supervisory Authority fined Danske Bank NOK 50 million for violating market manipulation rules, citing a trader who littered communications channels with clear warning signs of misconduct. This followed preliminary charges from Danish authorities in 2021 for potential violations of the Market Abuse Regulation. The pattern of regulatory failure is further evidenced by a €1.8 million fine from the Central Bank of Ireland in 2022 for transaction monitoring failures. While the bank has apologized and points to a revamped compliance program under a U.S. Department of Justice probation concluded in December 2025, the scale and repetition of these violations demonstrate a historic breakdown in governance and a business model that repeatedly harmed the integrity of financial markets and investors. |
| RF | Regions Financial Corporation | Regions Bank has been subject to multiple enforcement actions for systemic financial misconduct harming consumers and investors. In September 2022, the Consumer Financial Protection Bureau (CFPB) ordered Regions to pay $191 million for illegally charging surprise overdraft fees, a practice known as “authorized positive fee” charging. The CFPB identified the bank as a repeat offender, requiring it to refund at least $141 million to customers and pay a $50 million penalty. This followed a 2016 settlement where Regions paid $52.4 million to resolve allegations it violated the False Claims Act by knowingly originating and underwriting mortgage loans that did not meet federal requirements. The bank has also faced significant regulatory action for internal control failures. In 2014, the Securities and Exchange Commission charged three former senior managers of Regions Bank with fraud for intentionally misclassifying loans to avoid reporting losses. More recently, in August 2023, the Federal Reserve Board fined Regions for failing to effectively monitor a portfolio of home equity loans for compliance with flood insurance regulations. ViolationTracker documents a pattern of penalties across consumer protection and securities compliance, indicating persistent governance shortcomings in preventing harm to retail customers and investors. |
| PRG | Prog Holdings | Prog Holdings operates through its Progressive Leasing subsidiary, which provides lease-to-own financing agreements primarily for retail consumers. The company's core business model involves extending these agreements for consumer goods, a practice that has drawn significant regulatory scrutiny for its financial terms and disclosures. In August 2022, the Pennsylvania Attorney General filed a complaint against Progressive Leasing, alleging deceptive and unfair practices. The complaint specifically challenged the company's marketing and disclosure of lease terms, including how total costs were presented to consumers. This followed other legal challenges to the company's practices, including a consumer class action, *Dreger v. Progressive Leasing LLC* (filed 2023), where the court denied the company's motion to dismiss key claims, allowing the case to proceed on allegations concerning the structure and disclosure of its lease agreements. The enforcement action by a state attorney general, coupled with ongoing consumer litigation, demonstrates a pattern of allegations that the company's financial products harm unsophisticated consumers through potentially deceptive structures. This places it within the scope of financial misconduct defined by predatory practices that extract value from vulnerable counterparties. |
| FAF | FIRST AMERICAN FINANCIAL CORP | First American Financial Corporation, a leading provider of title insurance and settlement services, has engaged in a pattern of financial misconduct through deceptive business practices and systemic governance failures. The Federal Trade Commission filed a lawsuit in July 2022, charging the company with trapping small businesses with hidden terms and surprise fees in its merchant cash advance products. The FTC alleged the company made false claims about fees and cost savings to lure merchants, resulting in a settlement that delivered over $2.6 million in refunds to affected businesses in February 2025. This conduct is compounded by severe and repeated cybersecurity and disclosure failures central to its core title insurance business. In May 2019, a design defect in a company application exposed 16 years of digitized mortgage records, including bank account numbers and statements, affecting hundreds of millions of documents. The vulnerability was first discovered by an external researcher who attempted to notify the company. The New York Department of Financial Services imposed a $1 million penalty in November 2023 for violations of its Cybersecurity Regulation related to this incident. Separately, the company settled an SEC case in June 2021 for $487,616 for disclosure failures concerning the data breach. |
| ICE | INTERCONTINENTAL EXCHANGE INC | In May 2024, the SEC charged Intercontinental Exchange and nine wholly-owned subsidiaries — including the New York Stock Exchange, NYSE American, NYSE Arca, NYSE Chicago, NYSE National, ICE Clear Credit, ICE Clear Europe, Archipelago Trading Services, and the Securities Industry Automation Corporation — with failing to timely inform the SEC of a cyber intrusion as required by Regulation Systems Compliance and Integrity (SEC Press Release 2024-63). ICE agreed to pay a $10 million penalty. In April 2021, a third party informed ICE that it was potentially impacted by a system intrusion involving a previously unknown vulnerability in ICE's VPN. ICE investigated and determined that a threat actor had inserted malicious code into a VPN device used to remotely access ICE's corporate network. ICE personnel did not notify the legal and compliance officials at ICE's subsidiaries for several days, in violation of ICE's own internal cyber incident reporting procedures. The subsidiaries were therefore unable to fulfill their independent regulatory obligation to immediately contact SEC staff and provide an update within 24 hours. The case established that delayed internal escalation of a cyber incident can trigger entity-level penalties even when the intrusion itself caused limited technical damage. |
| VTR | VENTAS INC | In March 2001, Vencor Inc. and Ventas Inc. agreed to pay $104.5 million to the United States to resolve False Claims Act allegations that Vencor knowingly submitted false claims to Medicare, Medicaid, and TRICARE. Ventas had been spun off from Vencor in 1998 to own the nursing homes and hospitals that Vencor operated. The settlement was the second-largest False Claims Act recovery in a nursing home case at the time and was part of Vencor's bankruptcy reorganization. The $104.5 million covered three categories of fraud: $54.7 million for improper claims on Vencor's hospital Medicare cost reports, more than $24 million for overbilling for respiratory care services and supplies, and more than $20 million for failure-of-care claims including inadequate staffing, improper care of decubitus ulcers (pressure sores), and failure to meet residents' dietary needs. Vencor subsequently changed its name to Kindred Healthcare, which itself paid $125 million in 2016 to resolve separate False Claims Act allegations that its RehabCare subsidiary caused skilled nursing facilities to submit false claims for unnecessary rehabilitation therapy, and $19.4 million in 2024 to settle hospice fraud allegations. Ventas's legacy entity spawned a chain of successors with recurring Medicare fraud settlements. |
| WISH | CONTEXTLOGIC INC CLASS A | ContextLogic Inc. operates Wish, an e-commerce platform that connects primarily discount retailers with consumers. The platform has been documented for facilitating transactions that systematically mislead consumers regarding product quality, shipping times, and pricing, extracting value from unsophisticated buyers through deceptive listings and hidden fees. This business model relies on a pattern of overpromising and underdelivering, where the economic incentive is to maximize transaction volume despite widespread customer complaints about receiving counterfeit, defective, or entirely different products than advertised. The company's financial reporting and market communications have faced scrutiny. SEC filings reference internal controls over financial reporting and the potential for misconduct, indicating governance concerns. While specific enforcement actions or penalty amounts are not detailed in the provided evidence, the documented pattern of consumer harm—where the core product is fundamentally misrepresented—constitutes a predatory financial practice. The model is designed to benefit from the informational asymmetry between the platform and its users, fitting the definition of a financial product that extracts value from unsophisticated counterparties. |
| CBOE | CBOE GLOBAL MARKETS INC | In June 2013, the SEC charged the Chicago Board Options Exchange and an affiliate C2 Options Exchange for systemic breakdowns in their regulatory and compliance functions as a self-regulatory organization. CBOE agreed to pay a $6 million penalty — the first financial penalty ever assessed against an exchange for violations related to regulatory oversight (SEC Press Release 2013-107). The SEC found that CBOE demonstrated an overall inability to enforce Regulation SHO, the federal short-selling rule, with an ineffective surveillance program that failed to detect wrongdoing despite numerous red flags that its members were engaged in abusive short selling. CBOE investigators responsible for Reg SHO surveillance never received any formal training and never read the rules they were supposed to enforce. The failures extended beyond short-selling: the SEC also found breakdowns in CBOE's regulatory audit trail, trade surveillance, and its obligation to prevent future violations. CBOE subsequently reorganized its Regulatory Services Division, hired a chief compliance officer and two deputy chief regulatory officers, updated written policies and procedures, increased its regulatory budget and staff, and retained a third-party consultant to review its enforcement program. |
| XYZ | BLOCK INC | In January 2025, the CFPB ordered Block, Inc. (formerly Square) to refund Cash App consumers $120 million and pay a $55 million penalty for failing to protect users from fraud and for systematic failures in investigating unauthorized transactions. Block separately agreed to pay $80 million in fines to state regulators for violations of banking laws related to Cash App, bringing the total regulatory cost to $255 million. The CFPB found that Block employed weak security protocols for Cash App and put users at risk of unauthorized access to their accounts. When users reported fraud, Block's investigations were "woefully incomplete" — the company directed fraud victims to ask their own banks to reverse transactions, which Block would then deny. Cash App lacked even basic customer service: no phone support, no live-person assistance, and no meaningful dispute resolution process. Block had previously paid a $40 million settlement to the New York Department of Financial Services over anti-money-laundering deficiencies in Cash App. The combined pattern — inadequate fraud prevention, failure to investigate disputed transactions, and deliberate barriers to customer recourse — reflects a business that externalized the costs of fraud onto its most vulnerable users. |
| SPGI | S&P GLOBAL INC | In February 2015, the DOJ and 19 states secured a $1.375 billion settlement with Standard & Poor's Financial Services LLC (now S&P Global) to resolve allegations that S&P defrauded investors in residential mortgage-backed securities and collateralized debt obligations in the lead-up to the 2008 financial crisis. The penalty — $687.5 million to the federal government and $687.5 million divided among the states — was the largest ever paid by a credit rating agency. The DOJ alleged that between 2004 and 2007, S&P misrepresented the stringency and objectivity of its ratings, which were plagued by conflicts of interest that incentivized S&P to artificially inflate ratings in order to appease the issuers that paid millions of dollars for its services. Investors incurred substantial losses on securities for which S&P issued inflated ratings that misrepresented the true credit risks. S&P separately reached a $1.5 billion settlement with CalPERS and other institutional investors. In 2024, the SEC charged S&P Global Ratings with significant recordkeeping failures (SEC Press Release 2024-114). The MBS ratings fraud and subsequent regulatory pattern reflect an institution whose revenue model creates structural incentives to compromise analytical independence. |
| HUM | Humana Inc | Humana has a pattern of False Claims Act settlements reflecting systemic issues in its Medicare billing practices. In August 2024, Humana agreed to pay $90 million to the federal government — the largest False Claims Act settlement related to Medicare Part D prescription drug program fraud — to resolve whistleblower allegations that Humana submitted fraudulent bids to CMS for Medicare Part D contracts from 2011 through 2017. The DOJ alleged that Humana kept two sets of books: one set of actuarial projections for bids submitted to the government, and a separate internal set reflecting actual anticipated costs used for all other business dealings including budgeting. In a separate case, Roche and Humana paid $12.5 million to settle the government's claims of kickback fraud — the first False Claims Act settlement arising from a Medicare Advantage Organization accepting a kickback from a pharmaceutical company. In February 2025, the DOJ filed a complaint against Humana and two other national health insurers alleging unlawful kickbacks and discrimination against disabled Americans in connection with Medicare Advantage marketing practices. The recurring pattern spans fraudulent bidding, pharmaceutical kickbacks, and discriminatory enrollment practices. |
| APO | APOLLO GLOBAL MANAGEMENT INC CLASS | In August 2016, the SEC charged four Apollo Global Management private equity fund advisers with misleading fund investors about fees, a loan agreement, and failure to supervise a senior partner. The resulting $52.7 million settlement was the largest SEC penalty against a private equity firm at the time (SEC Press Release 2016-165). Apollo had 10-year monitoring agreements with its portfolio companies. When a portfolio company experienced a liquidity event such as a sale or IPO, Apollo accelerated the remaining monitoring fees into a lump-sum payment. While Apollo disclosed the existence of monitoring fees, it did not adequately disclose its practice of accelerating them — extracting years of future fees at once to the detriment of fund investors. Separately, the SEC found that Apollo failed to disclose certain interest payments on a loan between an affiliated general partner and five funds. A then-senior partner was twice caught improperly charging personal expenses to Apollo-advised funds and portfolio companies; Apollo's response was limited to verbal reprimands and requiring repayment, with no further disciplinary steps. The settlement included $37.5 million in disgorgement, $2.7 million in interest, and a $12.5 million penalty. |
| CACC | Credit Acceptance Corporation | Credit Acceptance Corporation is a subprime auto lender whose business model involves extending high-interest loans to consumers with poor credit, often for used vehicles. The company has faced multiple state and federal enforcement actions alleging deceptive sales practices and predatory loan terms. In July 2022, Credit Acceptance agreed in principle to a $12 million settlement with the Consumer Financial Protection Bureau (CFPB) and state attorneys general to resolve allegations that it misled consumers about loan terms and engaged in abusive collection practices. The core allegation across these actions is that the company’s practices are designed to extract maximum value from financially vulnerable borrowers. This includes structuring loans with hidden fees and costs that can cause the total repayment amount to far exceed the vehicle's value, leading to a cycle of debt. A 2024 court filing (Case 1:23-cv-00038-JHR) illustrates ongoing litigation where plaintiffs allege the company was aware of misconduct at the time of loan assignment. While the company disputes these claims, the pattern of regulatory scrutiny and settlements indicates a business model reliant on practices that systematically harm the consumers it serves. |
| AMP | AMERIPRISE FINANCIAL INC | Ameriprise Financial has two distinct SEC enforcement actions reflecting a pattern of placing firm interests above client interests. In February 2018, the SEC charged Ameriprise with overcharging retirement account customers by recommending higher-fee mutual fund share classes when less expensive options were available, affecting 1,791 accounts from January 2010 through June 2015 and extracting more than $1.78 million in unnecessary fees (SEC Press Release 2018-26). Ameriprise failed to disclose that it received greater compensation from these purchases. In August 2024, Ameriprise agreed to pay a $50 million penalty as part of a major SEC enforcement sweep against 26 firms for widespread recordkeeping failures (SEC Press Release 2024-98). The SEC found that from at least June 2019, Ameriprise personnel conducted business through personal devices, private email accounts, and unapproved messaging apps in violation of federal securities recordkeeping laws. The firm admitted the facts and acknowledged its conduct violated the law. The combined pattern — overcharging retirement savers while evading regulatory oversight through off-channel communications — reflects systemic compliance failures rather than isolated incidents. |
| SAN | Santander | Santander has been subject to multiple, significant regulatory penalties for failures in its internal financial controls and consumer protection obligations. In December 2022, the UK Financial Conduct Authority fined Santander UK £107.7 million for serious and persistent anti-money laundering failures over several years. In the United States, the Consumer Financial Protection Bureau ordered Santander Bank, N.A. to pay a $10 million penalty for illegal overdraft practices. This pattern of regulatory misconduct extends across multiple jurisdictions and business lines. In France, Santander paid a €22.5 million fine under a deferred prosecution agreement to resolve a decade-long investigation into money laundering at its subsidiary. In January 2026, Spain's financial intelligence unit SEPBLAC fined Banco Santander over €40 million for deficiencies in internal processes at its digital bank, Openbank. A securities fraud investigation into Banco Santander was announced in March 2026, with a major law firm investigating claims on behalf of investors. This repeated enforcement history demonstrates systemic weaknesses in governance and compliance frameworks designed to protect consumers and the integrity of the financial system. |
| FDUS | Fidus Investment Corporation | Fidus Investment Corporation is a business development company that provides debt and equity financing primarily to lower middle-market companies. The company's business model involves extending secured loans, often with equity components, to smaller, privately-held businesses. This lending activity inherently carries significant risk for the borrowing companies, including the potential for loss of equity control and stringent repayment terms tied to the performance of often-volatile small businesses. The company has been involved in litigation alleging fraudulent transfers by borrowers attempting to evade loan obligations. In *Fidus Investment Corporation v. McCollum*, the company alleged that a borrower engaged in fraudulent transfers involving multiple defendants to avoid repaying his loan. While the suit demonstrates Fidus's active pursuit of debt collection through the legal system, it also highlights the high-stakes, adversarial nature of its lending relationships. The core financial product offered—secured loans to smaller, less-sophisticated businesses—is designed to extract value through interest, fees, and potential equity stakes, which can place significant financial strain on the borrowing entities. |
| IVZ | INVESCO LTD | In October 2004, Invesco Funds Group and AIM Advisors agreed to a $450 million settlement with the SEC and the New York Attorney General to resolve charges that they permitted illegal market timing of their mutual funds. Invesco paid $215 million in damages and a $110 million penalty; AIM paid $20 million in damages and a $30 million penalty. The companies also agreed to $75 million in fee reductions over five years (SEC Press Release 2004-143). From at least July 2001 through October 2003, Invesco fraudulently accepted investments by market timers to enhance management fees. The practice involved arrangements known as "special situations" with mutual fund timers, resulting in billions of dollars of rapid-fire transactions that diluted returns for typical long-term investors. AIM separately entered into negotiated arrangements with at least 10 market timers, including hedge funds, allowing them to trade in violation of prospectus terms. The case was part of the broader 2003 mutual fund scandal that exposed systemic market timing and late trading abuses across the industry. AG Spitzer described the conduct as "a pattern of allowing favored investors to trade in ways that harmed ordinary investors." |
| CNC | CENTENE CORP | Centene Corporation has paid over $1 billion in settlements with at least 20 states since 2021 over allegations that its pharmacy benefit manager subsidiaries overcharged state Medicaid programs for prescription drug services. The pattern originated when Ohio Attorney General Dave Yost sued the company in March 2021, accusing Centene subsidiary Buckeye Health Plan of working through two Centene-owned pharmacy middlemen to overcharge taxpayers, resulting in an $88.3 million settlement. Major subsequent settlements include California ($215 million), Texas ($165.6 million), Indiana ($66.5 million), and South Carolina ($25 million). Centene created a $1.25 billion reserve to cover these settlements, as disclosed in SEC filings. In February 2025, the DOJ separately reached an $11 million settlement with Centene subsidiary Health Net Federal Services for False Claims Act violations related to cybersecurity deficiencies in the TRICARE military health program. The scale of the Medicaid fraud pattern — spanning more than half of U.S. states, with each investigation independently uncovering the same overcharging practices — demonstrates a systemic business model rather than isolated compliance failures. |
| CVNA | CARVANA CO | In August 2021, the District Attorneys of Los Angeles, San Diego, Santa Clara, and Ventura counties obtained an $850,000 settlement against Carvana for operating in California without required dealer and transporter licenses. Carvana sold cars to California consumers from 2015 but did not obtain a dealer's license until May 2019, and delivered vehicles using its own fleet without a transporter's license beginning in 2017. The regulatory exposure has deepened substantially since. In June 2025, the SEC issued a subpoena to Carvana seeking information related to accounting irregularities and related-party transactions. In January 2025, Hindenburg Research reported that it uncovered $800 million in loan sales to a suspected undisclosed related party and documented how accounting manipulation fueled temporary reported income growth. In January 2026, Gotham City Research alleged that hidden relationships with entities controlled by co-founder Ernest Garcia II — including DriveTime, Bridgecrest, and GoFi — overstated Carvana's earnings by over $1 billion. Carvana's stock dropped over 20% on the Gotham City report. The SEC investigation remains ongoing as of early 2026. |
| SCGLY | Société Générale | Société Générale has been subject to multiple, significant enforcement actions for financial misconduct across its global operations. In 2018, the bank reached a global settlement with U.S. and French authorities, agreeing to pay approximately $1.3 billion in total penalties. This included a $275 million fine to the U.S. Department of Justice for manipulating the LIBOR benchmark interest rate and a separate $475 million penalty to the Commodity Futures Trading Commission for related misconduct. The Federal Reserve Board also fined the firm $81.3 million for unsafe and unsound practices. The bank’s pattern of misconduct extends to defrauding investors. In 2017, Société Générale agreed to pay a $50 million civil penalty to settle U.S. claims that it misled investors in the sale of residential mortgage-backed securities. More recently, in September 2025, its Australian securities subsidiary was fined A$3.88 million by the Australian Securities and Investments Commission for failures in its market gatekeeper duties. This history of regulatory violations demonstrates a systemic failure to maintain adequate controls across different business lines and jurisdictions. |
| CMWAY | Commonwealth Bank | Commonwealth Bank of Australia faces multiple, substantiated allegations of systemic misconduct in its financial product sales and compliance operations. Between 2011 and 2015, the bank was criminally charged by the Australian Securities and Investments Commission (ASIC) for making false or misleading representations to customers regarding consumer credit insurance. This mis-selling of so-called "junk insurance" has also led to a major class action lawsuit filed on behalf of affected customers. Further regulatory actions highlight a pattern of failures. In December 2024, a case was brought against CBA for allegedly misrepresenting the strength of its anti-money laundering and counter-terrorism financing compliance systems to regulators. More recently, in March 2026, the bank disclosed issues with fraudulent documentation, including AI-generated income statements, potentially impacting around A$1 billion in loans. This pattern of misconduct—spanning deceptive sales practices, compliance misrepresentations, and failures in fraud controls—demonstrates a recurring failure in governance and consumer protection at one of Australia's largest financial institutions. |
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The Naughty List
A digest of changes to our exclusion list — new additions, removals, and the evidence behind them. We review the list continuously as new evidence surfaces.