Few legal cases capture the complex interplay between corporate ambition, environmental destruction, and public health hazards quite like the allegations against Black Hills Nebraska Gas, Brightspeed Kansas Holdings, and the Nebraska Public Power District (NPPD) in the legal documents attached to the Iowa-Nebraska Light & Power Company Superfund Site. At first glance, these sprawling pages of consent decrees, tables, and statutes read like a dry legal script. Yet they tell a searing story: one of serious corporate misconduct, alleged hazardous-waste mismanagement, and the high-stakes struggle for corporate accountability.

In these documents, the U.S. Environmental Protection Agency (EPA) cites the defendants under the Comprehensive Environmental Response, Compensation, and Liability Act (CERCLA) for contamination at the Iowa-Nebraska Light & Power Company Superfund Site, located in Norfolk, Madison County, Nebraska. The most damning allegations refer to decades-old industrial practices that produced contaminants including heavy metals, volatile organic compounds (VOCs), benzene, and polycyclic aromatic hydrocarbons (PAHs). These substances seeped into the soil and groundwater, creating a serious threat to public health and the broader ecosystem.

Even with remedial actions already underway—such as the excavation of thousands of tons of contaminated soils and the proposed in-situ thermal treatment—these allegations underscore a broader systemic problem. Under neoliberal capitalism, where deregulation, profit maximization, and corporate self-interest often undermine stricter oversight, corporations can sidestep or downplay their responsibility for harm to the public. Regulatory capture and legislative loopholes further entrench an economic model in which communities bear the social and economic fallout.

The allegations describe how these defendants, each with a piece of ownership or operational responsibility for a contaminated former manufactured gas plant (FMGP) site, face claims of releasing hazardous materials into the environment. Specifically, the complaint and settlement (the Consent Decree) describe steps for cost reimbursement, mandatory cleanup (via soil excavation and in-situ thermal treatment), groundwater monitoring, and legal frameworks for how the parties must prevent future contamination. Yet behind the remedial specifics lies a deeper cautionary tale of industrial disregard.

This investigative article draws on those allegations to connect the local situation in Norfolk to the global phenomenon of corporate greed and the moral hazards of late-stage capitalism. Section by section, we explore the gravity of these claims, the multi-layered cost to local communities, and the persistent pattern of corporate behavior that emerges when wealth accumulation outpaces moral or regulatory constraints. Through these allegations, we see how deregulation, a toothless enforcement environment, and an economic ideology that prioritizes shareholder returns contribute to ongoing environmental threats.

Above all, the facts contained here—drawn specifically from the attached legal source—illuminate how the best intentions of environmental and public health laws can become compromised when large institutions focus single-mindedly on profit. The result is often a slow-moving public-health crisis that local communities, already marginalized by wealth disparity, must confront. By analyzing the alleged misconduct, we grasp how systemic failures ripple beyond a single Superfund site to raise unsettling questions: Will corporate actors truly reform? Or will the same perverse incentives drive repeated episodes of corporate pollution and negligence?

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Corporate Intent Exposed

According to the attached Consent Decree, the Iowa-Nebraska Light & Power Company Superfund Site in Norfolk was once an active manufactured gas plant (MGP). Beginning operations around the turn of the 20th century, this facility reportedly released coal tar residues, heavy metals, and other toxic by-products into the soil and groundwater. These pollutants, including benzene and naphthalene, pose grave threats to human health—benzene alone is a known carcinogen.

The legal documents outline a wide array of alleged “performance obligations” that the defendants—Black Hills Nebraska Gas, Brightspeed Kansas Holdings (successor to Centel Corporation), and NPPD—must now fulfill. While the agreement never explicitly uses the phrase “corporate intent,” the scope and scale of negligence implied leaves little doubt that profit-driven motives and operational disregard for the environment collided to create this hazard.

1. Extended Timeline of Neglect
   • The site’s contamination stretches back decades, with multiple owners or operators leaving behind a toxic legacy. Over time, spillage and runoff from MGP operations and possibly leaky underground storage tanks led to soil and groundwater contamination.
   • The allegations imply that each entity had knowledge or should have had knowledge of the looming risk to local communities.
2. Documents that Reveal Knowledge
   • Although we have no invented memos or direct quotes, the Consent Decree references repeated site investigations in the early 1990s, followed by more thorough expansions in the 2000s. These were presumably mandated under CERCLA.
   • By the mid-2010s, the U.S. EPA had enough evidence to classify the site on the National Priorities List (NPL), concluding that contamination was severe enough to warrant federal oversight.
3. Denials and Partial Admissions
   • The Consent Decree notes that the settling defendants “do not admit any liability” for alleged misconduct, but they also did not disclaim that contamination had occurred. This legal stance is not unusual: corporations often settle or agree to consent decrees without formally conceding wrongdoing.
   • This partial acceptance is consistent with broader corporate patterns, where firms tactically cooperate under settlement to manage public relations while resisting direct admissions that might heighten future liability.
4. Key Contaminants and Pathways
   • The chemical stew includes polycyclic aromatic hydrocarbons (PAHs) like naphthalene, as well as benzene, ethylbenzene, and xylene.
   • These toxins travel through soil into groundwater, potentially threatening local municipal water supplies. Indeed, the east municipal well field is only half a mile downgradient from the site.

Within these pages, one gleans an image of a corporate approach that, at best, overlooked the true ecological and health hazards posed by MGP by-products, and at worst, knowingly downplayed them in pursuit of cost savings. As we delve further, the specificity of this alleged misconduct is crucial for shedding light on the deeper structural forces at play.

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The Corporations Get Away With It

Even as the Consent Decree demands compensation and prescribes a thorough remedial plan, I see the final settlement as being representative of how “the corporations get away with it.” Indeed, the defendants are required to finance site cleanup, reimburse the EPA’s costs, and remain subject to long-term oversight. Yet from a broader socio-economic perspective, the cost to the companies may remain modest relative to their collective assets.

1. Civil Settlements and Their Limitations
   • The settlement includes a Remedial Action plan: in-situ thermal treatment, indemnification clauses, and financial assurance mechanisms. However, these steps do not necessarily suffice to penalize an entity if it can absorb or pass on those costs to consumers or local ratepayers.
   • Environmental compliance often becomes “the cost of doing business” for corporations.
2. Regulatory Capture or Under-Resourcing?
   • The very existence of a legally binding Consent Decree suggests that environmental laws have some teeth. However, repeated expansions of the site’s investigation and enforcement phases hint at the challenges the EPA faced over time.
   • In an era of neoliberal capitalism, environmental agencies often lack the budget or staff to hold large corporations fully accountable for their pollution. Even when agencies do issue fines or mandate cleanup, companies can negotiate terms behind closed doors, or simply treat fines as a line item.
3. Long Cleanup Timelines
   • The timeframe for final closure can stretch for years or decades, with multiple five-year reviews and indefinite site monitoring. Meanwhile, local communities continue living amid the threat of benzene-laced groundwater.
   • In the event of corporate restructuring or bankruptcies, local communities may shoulder the burden if trust funds or financial assurances prove inadequate.
4. Subtle Ways of Evading Full Responsibility
   • Through disclaimers, the defendants do not admit fault. This legal nuance preserves the corporations’ flexibility. They can move forward operationally, raising capital and distributing dividends as if the environmental crisis were a footnote.
   • Meanwhile, residents who suspect their health has been jeopardized by corporate pollution must navigate legal complexities to secure compensation for medical bills or property devaluation.

To be fair, the settlement does impose an aggressive remedy: the in-situ thermal treatment of impacted soils, rigorous groundwater monitoring, and ongoing financial obligations. Yet the cumulative effect is that many see these measures as merely the legislative minimum necessary. The system remains skewed to let big corporations continue operating and profiting—often at the expense of vulnerable communities—while paying for environmental damage only when absolutely compelled by a regulatory settlement.

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The Cost of Doing Business

When corporate leaders push for maximum efficiency and shareholder returns, environmental safeguards often become afterthoughts. This pattern is visible in the Iowa-Nebraska Light & Power Company Superfund Site: the alleged contamination that spanned decades, along with the complex remediation scheme, can be analyzed as a direct outcome of corporate profit-maximization strategies under an economic system that offers limited constraints.

1. Financial Allocation vs. Site Restoration
   • The legal source sets forth a requirement for the settling defendants to provide Financial Assurance, ensuring adequate funding for the in-situ thermal treatment, groundwater monitoring, and other cleanup tasks. The cost estimate runs into millions, just for the near-term activities, plus indefinite future monitoring.
   • Yet many wonder: had robust environmental controls been installed earlier—say, vapor or water treatment systems during the height of MGP operations—would these lawsuits have arisen? Cheaper upfront investment in safety might have prevented a multi-million-dollar settlement. But under the typical “short-term cost/long-term hazard” approach, corporations often push risk into the future.
2. Contamination as an Externality
   • Under neoliberal economic doctrine, environmental harm is often framed as an “externality”—a cost not factored into the price of the final product or corporate operations. Because profits are privatized, but pollution’s costs (e.g., medical bills, water treatment, environmental restoration) become communal, there is insufficient internal corporate incentive to reduce hazards.
   • The Consent Decree attempts to reverse that dynamic by forcing the defendants to internalize at least some of the cleanup costs. But by the time of enforcement, the environment and public health have already suffered.
3. Public-Private Funding Disconnect
   • The site was placed on the National Priorities List (NPL), indicating that federal resources also help cover investigative costs. This means taxpayer funds have been spent on investigating contamination.
   • Although the final settlement reimburses the EPA for future response costs, repeated cycles of partial reimbursements do not address the intangible losses local residents have sustained—decreased property values, potential health risks, and a degraded environment.
4. Leverage Over Local Economies
   • Entities like NPPD and Brightspeed Kansas Holdings are deeply embedded in local economic structures. NPPD is a public power utility, arguably more accountable to local constituencies, yet still facing allegations of cost-shifting pollution burdens.
   • For their part, corporations often employ local workers and provide tax revenue. This can give them outsized leverage in negotiations with regulators, especially in smaller towns reliant on major employers.

All these factors converge to suggest that, under the typical corporate calculus, environmental oversight becomes an afterthought. The tens of thousands of pages of engineering designs, legal definitions, and lengthy obligations contained in the Consent Decree reflect an attempt to remedy decades of harm. Whether or not that remedy will suffice or produce full accountability is a question haunting many residents of Norfolk.

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Systemic Failures

Beyond the site-specific allegations, the Iowa-Nebraska Light & Power Company’s contamination reveals structural weaknesses in regulatory enforcement. Under neoliberal capitalism, these weaknesses tend to favor corporate prerogatives over robust environmental stewardship.

1. The Role of Deregulation
   • Over the past several decades, repeated calls for deregulation have limited the government’s capacity to impose stringent environmental standards. In some instances, corporate lobbyists have pushed for exemptions, relaxed standards, or reduced inspection schedules.
   • Although the Superfund program remains a critical tool for the EPA, it is not designed for quick fixes. Many Superfund sites remain in limbo for years, burdened by constrained agency budgets and procedural complexities.
2. Regulatory Capture
   • This phenomenon arises when agencies meant to regulate big business become dominated by the very interests they’re supposed to police.
   • While no direct evidence from the attached Consent Decree suggests undue corporate influence, the decades-long lapse between the site’s initial operation and ultimate legal settlement does feed speculation that regulators are reactive rather than proactive.
3. Limited Punitive Measures
   • Under existing CERCLA structures, the government can recover costs for site cleanup and impose fines for non-compliance with unilateral orders or consent decrees. Yet the legal system rarely criminalizes environmental wrongdoing—particularly the mid-level decisions that led to contamination in the first place.
   • This fosters a business environment where executives rationally weigh the risk of a future settlement or fine against present-day profits and shareholder demands.
4. Community Disempowerment
   • Many local communities, especially in smaller or rural areas, lack resources to conduct independent technical analyses or to mobilize large-scale advocacy.
   • While the consent decree and the NPL listing aim to remediate damage, local residents, especially the economically vulnerable, can feel sidelined. They must rely on the government to act on their behalf, without the direct means to press for stricter penalties or restitution for intangible harms.

The net result is a patchwork system that struggles to address big industrial polluters comprehensively. Although it can achieve partial remediation, it seldom exacts a penalty severe enough to reshape corporate behavior at its root. Indeed, for corporations with substantial financial backing, even multi-million-dollar settlements can be an acceptable trade-off.

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This Pattern of Predation Is a Feature, Not a Bug

This entire scenario a textbook example of “corporate greed,” illustrating how wealth disparity, public-health threats, and environmental injustice are often embedded in modern capitalism.

1. Profit Margins Trump Public Safety
   • The historic timeline at the site suggests that cost savings likely played a dominant role. The failure to line pits thoroughly or to properly dispose of manufacturing by-products looks suspiciously like a corner-cutting measure.
   • Even if the original decision-makers rationalized these as cost-saving or standard industry practice at the time, communities often have no remedy until decades later, after contaminants have migrated widely.
2. Socializing Risks, Privatizing Gains
   • The fundamental premise behind public limited liability corporations allows them to reap profits while socializing certain risks, particularly long-tail environmental liabilities.
   • This same pattern emerges repeatedly across industries, from petrochemical plants on the Gulf Coast to agricultural runoff in the Midwest. The corporations responsible for polluting the air, soil, and water rarely pay the full costs of the harm they inflict.
3. Inequality Magnifies the Impact
   • Many Superfund sites are located in or near communities that already face economic challenges. Historically redlined neighborhoods, minority communities, or rural towns dependent on a single employer are the easiest sites for pollution to persist unnoticed or unchallenged.
   • In the Norfolk region, members of the community who lack the financial capacity to move away must continue to rely on local water supplies, or face a stigma affecting property values.
4. A Template of Corporate Conduct
   • The repeated references to “no admission of liability” in the Consent Decree highlight an industry-wide legal approach: do the cleanup only if legally cornered, avoid direct statements of wrongdoing, and pay out minimal damages. This approach ensures minimal repercussions for corporate boards and executives.
   • In this sense, the allegations and partial remedy here highlight a recurring pattern. Rather than a glitch in the system, they are arguably proof that the system is functioning as intended—for the corporations.

From this vantage point, one can see that the corporate logic fostering environmental harm is not an isolated phenomenon. It’s built into broader capitalist structures that prioritize short-term gains over long-term public welfare. Only robust regulation and unwavering enforcement can balance the scales—but those are precisely what are eroded by decades of lobbying, budget cuts, and ideological hostility toward government oversight.

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The PR Playbook of Damage Control

While the Consent Decree compels the settling defendants to fund and carry out the Remedial Action, they also typically deploy a public relations (PR) playbook to mitigate reputational risks. The attached legal source reveals no direct internal memos or confessions, but the settlement structure hints at typical corporate PR strategies in the face of environmental scandal.

1. Messaging That Downplays Harm
   • In external communications, corporations commonly emphasize that they are “committed to the community’s safety” and “cooperating fully with regulators.” This can keep local consumers’ trust intact and quell demands for deeper investigations.
   • The partial truths behind these statements—like the fact that cooperation was mandated by a legal decree—often go unmentioned.
2. Highlighting Incremental Improvements
   • By stressing that they have “already excavated 10,495 tons of contaminated soil” or are “conducting continuous groundwater monitoring,” these corporations portray themselves as responsible and forward-thinking.
   • The subtext suggests that community members should be grateful for these steps, despite the reality that these are belated obligations, not altruistic gestures.
3. Shifting Blame to Past Operators
   • The legal settlement involves multiple corporate entities, each with inherited liabilities from predecessor companies. A typical PR strategy is to say, “This contamination occurred under earlier ownership,” thereby diminishing their own moral culpability.
   • In reality, corporate successions often carry both assets and liabilities. The fact that the corporate entity is the legal successor for some benefits means it is also responsible for the burdens.
4. Portraying the Settlement as a Win-Win
   • Another frequent corporate tactic is to declare the settlement a “positive resolution” that fosters a “healthier environment” and “supports the local economy through job-creating cleanup activities.” While partially true, it can overshadow the fundamental harm that triggered the settlement.
   • The risk is that ongoing, unremedied impacts, such as potential long-term vapor intrusion or slow-moving groundwater plumes, slip out of public memory if overshadowed by well-funded “positive messaging.”
5. Corporate Social Responsibility (CSR) Rhetoric
   • In an era where “corporate social responsibility” is a buzzword, entities often cite philanthropic grants or green initiatives as evidence of their broader commitment to the environment.
   • Such CSR marketing rarely addresses the root problem or acknowledges that, absent the EPA’s enforcement, the contamination might never have been cleaned up to safe standards.

In sum, the PR dimension underscores how the defendants aim to control the narrative while the deeper institutional structures enabling the pollution remain largely intact. Public statements do not mention how close the contamination was to municipal wells, nor do they dwell on the possible health toll. Instead, the emphasis is on “progress.” This underscores the importance of independent media scrutiny and citizen oversight in holding these corporations fully accountable.

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Profits over People

Once again, the bottom-line reality emerges: the allegations in the legal documents show how corporate operations—for decades—have put profits over people. If a safe and thorough disposal system had been installed initially, it would have cut into short-term profits. But historically, manufactured gas plants often stored or disposed of tar-based materials in suboptimal ways, burying contaminated waste on site to avoid disposal costs.

1. Benzene and Carcinogens in Local Water
   • The worst-case scenario is that these contaminants may reach municipal wells or a private well if one had been drilled outside the mandated restricted zone. The local community’s potential health impacts—cancer risk from benzene exposure, among others—are no small matter.
   • Although the Consent Decree includes robust monitoring to ensure compliance, it’s a reactive measure. People living near the site may have already experienced prolonged low-level exposure for years.
2. Economic Fallout
   • Once an area is declared a Superfund site, property values often decrease. Even after partial cleanup, the stigma can persist, limiting local investment and making it harder for families to sell their homes.
   • Ultimately, the local economy bears the brunt of industrial carelessness. Residents pay higher taxes to support public agencies dealing with site investigations, or they finance the costs of relocating if they fear contamination.
3. Wealth Disparity
   • If these corporate owners were to face an existential threat from environmental lawsuits, they might muster the lobbying clout or political capital to shape less restrictive policies. Meanwhile, families in Norfolk have limited recourse if contamination triggers medical crises or property devaluation.
   • This scenario feeds the cycle of wealth disparity, as the wealthy owners or shareholders remain largely insulated, while poorer residents cope with potential health hazards.
4. Ongoing Public-Health Dangers
   • Although the remedy—particularly the in-situ thermal treatment—aims to aggressively remove or destroy soil contamination, the deep aquifers that might still harbor residual chemicals remain a concern.
   • This highlights how “corporations’ dangers to public health” linger even after official documents declare the site remedy in place. If vigilance wanes, contamination can resurface or shift over time.

At heart, a system that prioritizes quick profit sees any measure that reduces short-term margins—like advanced pollution controls—as an optional expenditure. The consequence is an environmental time-bomb that can detonate years later, leaving communities to sift through the wreckage.

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The Human Toll on Workers and Communities

Though the Consent Decree itself focuses on remediation responsibilities and cost reimbursements, it inevitably touches on deeper human realities. For the Norfolk area, the threat of lingering soil and groundwater contamination is not purely hypothetical; real families may worry about vapor intrusion, real farmers may question if their irrigation water is safe, and real small businesses may face difficulties if the area’s reputation is damaged.

1. Workers’ Exposure Risks
   • Historically, employees at the old MGP or workers performing excavation at the site could have faced direct contact with coal tar or inhaled toxic fumes.
   • While the decree ensures site workers receive proper safety gear, the question remains: what about those who worked at the site decades ago without adequate protective equipment?
2. Community Health
   • Even if direct ingestion of contaminated water was limited, repeated exposure to soil vapors or dust might have subclinical effects on the population. The science of low-dose chemical exposure is evolving, but certain chemicals like benzene are known carcinogens.
   • The attached legal source references the recognized necessity of consistent monitoring. Still, residents might remain uncertain whether it’s truly safe to garden in their yards or let children play in areas near the site.
3. Social Anxiety and Distrust
   • Environmental crises often erode community trust. Conflicting statements from corporate representatives, state health agencies, and the EPA can sow confusion.
   • Over time, a culture of skepticism arises, with the public questioning whether the entire truth about contamination is being disclosed.
4. Cumulative Social Justice Concerns
   • Norfolk is not the only American town grappling with an MGP or industrial pollution legacy. Repetitive site patterns show up in older industrial corridors from the Midwest to the East Coast.
   • Typically, it is not wealthy suburbs but modest neighborhoods that find themselves stuck with contaminated soils. This reality underscores that environmental injustice intersects with class and sometimes with race or ethnicity as well.

For many who live near the site, the legal remedy and compensation can feel tardy and incomplete. The intangible loss, from missed days of work to heightened fear of cancer, underscores the real emotional cost. The human toll stands as a compelling reminder that public health cannot be protected by partial compliance.

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Global Trends in Corporate Accountability

The story unfolding in Norfolk is not unique. Across the globe, communities in Southeast Asia, Latin America, and Africa endure contamination from factories and mining operations with little recourse. In wealthy nations like Germany or Canada, stricter environmental laws somewhat mitigate harm, but corporate misbehavior is hardly unknown.

1. Parallel Cases
   • The classic model is the polluted region, often discovered well after the polluting facility has closed or changed ownership.
   • The corporation in question, or its corporate successor, contends it complied with then-existing standards. Regulators eventually declare the site a hazard, culminating in a lengthy legal or remedial process.
2. Fragmented Enforcement
   • Each country has its own version of environmental law, from the U.S. Superfund to the EU’s Environmental Liability Directive. This fragmentation can let multinational corporations shift operations or complicate cross-border legal accountability.
   • The result: if a corporation is pressured in one jurisdiction, it can restructure or move certain aspects of its business elsewhere.
3. Rising Demands for Corporate Transparency
   • Movements like the Right-to-Know and the push for ESG (Environmental, Social, Governance) criteria in investment markets reflect grassroots demands for clearer corporate accountability.
   • However, the current system often focuses on voluntary disclosures and community-liaison boards that lack legal force. As the Superfund allegations show, real accountability typically only arises from mandatory orders and enforcement decrees.
4. Neoliberal Logic in Overdrive
   • The broader neoliberal context fosters an environment where corporations remain fixated on cost-cutting to compete in deregulated markets.
   • Even well-intentioned managers struggle against shareholder demands for consistent dividend growth. Real structural change may necessitate revising corporate charters and shareholder priority norms.

Thus, the Norfolk settlement, though geographically specific, resonates with a global story of corporate ethics under capitalism. The question remains how far the existing legal frameworks can push corporations toward genuine reforms—rather than partial compliance.

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Pathways for Reform and Consumer Advocacy

Amid these sobering reflections, there remain possible solutions. The Iowa-Nebraska Light & Power Company Superfund Site example can serve as a catalyst, inspiring stronger legislation, more vigilant enforcement, and expanded activism.

1. Stronger Enforcement, Bigger Fines
   • One straightforward approach is imposing more substantial penalties that truly hurt a company’s bottom line, so they cannot merely treat environmental compliance as a footnote.
   • Fines must exceed the cost of compliance; otherwise, corporations rationally choose to cut corners.
2. Preventative Requirements
   • Requiring real-time monitoring systems for known hazards and immediate data-sharing with the local community can deter polluters from ignoring early warnings.
   • Mandating technology upgrades for high-risk processes—like MGP residual disposal—could prevent repeated “spill and pay” scenarios.
3. Independent Citizen Oversight
   • Communities can establish independent watchdog committees equipped with resources for technical experts to interpret data.
   • This fosters transparency and ensures local voices are heard, thereby reducing the risk of regulatory capture.
4. Leveraging Consumer Advocacy
   • Consumers can factor in corporate track records on pollution when selecting utility providers or lenders. This, however, presumes that consumers have robust “choice,” which is often lacking in utility monopolies or oligopolies.
   • Socially responsible investing or boycotts might motivate executives to internalize the real cost of polluting, but only if widely adopted.
5. Reclaiming Corporate Accountability
   • Ultimately, public policy that redefines corporate duties beyond narrow fiduciary obligations to shareholders is key to curbing the cycle of environmental disasters.
   • Some reformers urge rewriting corporate charters to require stakeholder representation, including local communities and employees, in major corporate decisions.

In the end, the attached Consent Decree addresses a single site, though an emblematic one. The push for thorough remedial actions—like in-situ thermal treatment—and the carefully delineated financial assurance requirements represent a partial success, forcing polluters to internalize some responsibilities. Yet these gains will be hollow unless bigger shifts occur: a transformation in how we expect corporations to behave, how government and communities enforce accountability, and how the law punishes or prevents corporate corruption and greed.

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The Department of Justice has a website where you can read this story: https://www.justice.gov/enrd/media/1375916/dl?inline

💡 Explore Corporate Misconduct by Category

Corporations harm people every day — from wage theft to pollution. Learn more by exploring key areas of injustice.

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• 🌿 Environmental Violations — Pollution, ecological collapse, and unchecked greed.
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• 💵 Financial Fraud & Corruption — Lies, scams, and executive impunity.