In the last week, we have learned that Wells Fargo has fired more than 5,300 employees and will pay $190 million in penalties and fines in the wake of an ongoing and widespread fraud scheme. The fraud involved the opening of more than 2 million accounts, which customers never authorized but were charged for.

The sheer number of accounts, number of employees losing their jobs and the total fines Wells Fargo will pay, are astounding and newsworthy on their own.

Personally, I am more intrigued by the information Acuity Forensics is finding in the follow-up stories coming out this week. It is the information in these stories that could spell real trouble for Wells Fargo. The threat they are facing isn’t the loss of the employees or the loss of money they will pay in fines. The real trouble facing Wells Fargo is what I call a “culture crisis”.

Last week we found this article, stating that Wells Fargo executive Carrie Tolstedt, in charge of the very unit deeply involved in the fraud, will retire early and walk away with more than $95 million in stock.

Wells Fargo has gone so far as to put their CEO John Stumpf on the “campaign trail” with major news media. His message? The fraud was the “responsibility of low level employees.”

The pieces of this puzzle tell an interesting story. A widespread, systemic fraud, involving thousands of employees, and millions of unauthorized accounts, opened for the sole purpose of meeting sales and commission goals. The walking away, with nearly $100 million, by the executive in charge of the unit perpetrating the fraud. And the CEO shaming the position of the very employees who lined his pockets, because surely, these frauds equated to profits. And what do profits generally equate to? Higher pay and higher stock prices.

In our experience, it is not typical for widespread, systemic fraud to be perpetrated in a vacuum or unbeknownst to management. Simply put, 5,300 employees don’t participate in a fraud unless it is known, out in the open, and accepted practice.

And where do 5,300 employees opening more than 2 million accounts understand accepted practice? From the top. From the CEO, to the Executives, to the Managers.

If you’re reading this, you’ve been an employee, a manager, an owner somewhere in your lifetime. In each of those organizations, how much power did the low-level employees have? How much decision-making authority?

None.

Why do 5,300 otherwise honest, hard-working employees participate in a fraud in the first place? Typically, it starts with Pressure. Pressure to perform, meet sales goals, earn commissions. But, pressure goes deeper than monetary pressure.

Pressure includes the pressure to be included in a group of co-workers and not be considered an “outsider”. Pressure includes the pressure to keep one’s job and pay one’s rent and keep one’s medical benefits. Pressure includes the prestige of having a great job at a “great bank” and pressure includes avoiding the stigma of suffering a job loss.

It is my experience that this kind of fraud could not have happened unless Wells Fargo’s management sent the message that money and numbers were more important than anything. The pressure came from the top and trickled down.

Wells Fargo then sent another message. A message to its high-level executives.

It’s okay. You can oversee and facilitate one of the largest and most-systemic frauds in banking history, and not only keep your job, you can walk away on your own terms with an obscene amount of stock options.

When you make crimes okay, when you make the consequences of overseeing and having knowledge about significant frauds equivalent to winning the lottery, there will be a trickle-down effect. More frauds will occur. More harm will be done. And when caught, what will those perpetrators say? Nothing. They won’t need to. They need only to point to Ms. Tolstedt and ask for the same deal she received.

One only need to look at Mark Whitacre, otherwise known as “The Informant” to understand the importance of sanctions when fraud is uncovered. He knew that a former C-suite executive had stolen millions from the organization and when caught? That executive walked away with stock options, a company car, and little more than a pink slip. In several interviews, Mr. Whitacre figured that the worst that could happen to him would be the same deal that the former executive had received.

As we place the pieces of the Wells Fargo puzzle into their proper places, then the picture becomes clear. The picture reveals a set of arrows, pointing in the direction of the C-suite and Mr. Stumpf, himself. The place where messages of “more profits” and “more money” and “it wasn’t me” come from.

With a message such as that, a forensic accountant like me can’t help but be pessimistic about Wells Fargo’s ability to change its corporate culture and find its way back to ethical, responsible, and accountable practices.

Are the investors and their representatives on the Wells Fargo Board of Directors going to stay silent? Accept the message as is?

Or, are they going to take the courageous step to change the message and reset the bank’s ethical tone?

How about starting with “I’m sorry” followed by “We were wrong”?

Over time, with actions that include ethical messaging, integrity in account management, and follow through when employees are charged with unethical or illegal behavior, Wells Fargo’s culture will thrive, and the puzzle picture will instead reveal a bright future.