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Issue #4 — Wells Fargo and the Number That Ate the Bank Read More

Issue #4 — Wells Fargo and the Number That Ate the Bank

By Kevin Brenner | Friday, June 12, 2026  Not Good is not an indictment of the companies it…

Issue #3 — Theranos: The Board That Was Built Not To Ask Read More

Issue #3 — Theranos: The Board That Was Built Not To Ask

Theranos had one of the most prestigious boards in America, and one of the least effective. A study of how the board’s missing oversight enabled the fraud, and what it teaches about building boards that verify rather than vouch.

The Rise of the “Fractional Specialist”: Why Legal Teams Are Quietly Rewriting Their Hiring Playbook Read More

The Rise of the “Fractional Specialist”: Why Legal Teams Are Quietly Rewriting Their Hiring Playbook

By: Daniel Santos, Special Counsel | May 29, 2026 Daniel Santos Helping Healthtech CEOs &…

Not Good: Bad Acts, BIG Costs   Issue #2 — Dieselgate: Ten Monkeys, One Beetle, and Cartoons Read More

Not Good: Bad Acts, BIG Costs Issue #2 — Dieselgate: Ten Monkeys, One Beetle, and Cartoons

In Issue #2 of Not Good, Kevin Brenner examines Dieselgate — how Volkswagen’s defeat-device software, an industry-funded monkey exhaust study, and years of concealment from regulators produced over $25 billion in penalties, multiple prison sentences, and a lasting lesson in what happens when compliance risk becomes personal risk.

The New Board Question: “What’s Our Exposure to AI‑Driven Misconduct?” Read More

The New Board Question: “What’s Our Exposure to AI‑Driven Misconduct?”

Two companies, same AI tools, totally different risk profiles. Daniel Santos on the new board question — “What’s our exposure to AI-driven misconduct?” — and why AI accountability, not technology, decides whether your governance holds up under scrutiny.

Red Flag: The Vendor Requested Far More PHI Than the Service Required Read More

Red Flag: The Vendor Requested Far More PHI Than the Service Required

A vendor deal that looked routine — clean MSA, sensible pricing, BAA already in place — almost moved forward in minutes. Then the SOW revealed a PHI request far beyond what was actually needed. Robyn D. Marino on why HIPAA compliance doesn’t stop at the BAA, and how SOW-level review changes the risk calculus on healthcare vendor agreements.

“When home.” How a two-word email subject line became part of a $650 million federal case. Read More

“When home.” How a two-word email subject line became part of a $650 million federal case.

By Kevin Brenner | Friday, May 22, 2026 Not Good is not an indictment of…

Do we still need to care about the FCPA? Read More

Do we still need to care about the FCPA?

By: Kevin Brenner, Esquire I’m hearing a surprising version of the same question from clients…

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