Risky Business

Project 2025 called for streamlining financial regulation by merging agencies, eliminating regulations, and repealing provisions of the Dodd-Frank Act designed to mitigate the risks posed by systemically important institutions. The Trump Administration is following a different agenda which neither weakens regulation nor tightens it in a way that promotes consumer protection or economic stability.

Instead, Trump’s agencies are conducting a MAGA-style ideological offensive against the big banks that seems designed to promote some of the president’s personal grievances. Chief among those is the claim that certain individuals and organizations are being denied access to banking services because of their political orientation or religious affiliation.

This allegation, which goes by the name debanking, has just been elevated from a conspiracy theory to the official position of the federal government through the publication of a 47-page report by the Treasury Department’s Office of the Comptroller of the Currency.

OCC’s arguments and evidence are flimsy, and the report fails to provide a clear explanation of the origins of the debanking controversy. There are two different sources. To some extent, the issue is the outgrowth of the resentment Trump feels toward banks that were reluctant to do business with him and his family company in the wake of the January 6 riot.

As part of his ongoing effort to rewrite the history of that event, Trump is seeking to delegitimize the concerns banks had about providing services to someone who seemed like he might be charged with inciting an insurrection.

The other source goes back further, to the late 1990s, when progressive activists began targeting banks such as Citigroup for lending to corporations that caused serious harm to the environment or were engaged in other destructive activities. In some cases, the banks themselves were investing in controversial projects.

Those campaigns were not always successful, but they sometimes had a big enough impact on the reputation of the banks that many federal and state regulators decided this was something the financial institutions had to treat as a risk factor. References to reputation risk became more and more common in bank examination guidance and handbooks.

OCC’s report is full of pejorative references to the concept of reputation risk. It and other federal agencies have been removing that concept from their supervisory systems, even though it is normally the role of regulators to encourage corporations to pay attention to risks of all kinds. Banks may respond to the banning of reputation risk rules by doing more business with clients engaged in controversial activities such as fossil fuel production.

It is unclear whether the Trump Administration has a master plan with this or is simply lashing out at perceived adversaries. It is odd that agencies such as the OCC are in effect telling banks to be less cautious in choosing their borrowers at the same time they are punishing banks for being insufficiently rigorous in their anti-money-laundering practices, which require more scrutiny of clients. Just recently, the OCC and Treasury’s Financial Crimes Enforcement Network fined Bank of America more than $1 billion for AML deficiencies.

All this is another indication that the Trump Administration is no longer pursuing any sort of coherent regulatory policy and is instead weaponizing federal oversight in the service of narrow ideological ends.

The Trump Administration Discovers Money Laundering

The Trump Administration cannot seem to make up its mind about whether to be serious about prosecuting banks and other financial entities for failing to fully live up to their responsibilities to deter money laundering.

Last year, after Trump returned to office, there were no announcements of resolved anti-money-laundering deficiency (AML) cases against banks. There were two big settlements with cryptocurrency firms—Peken Global and OKX—but these were the result of investigations begun under Biden. During the first half of this year, there were only a handful of AML case resolutions, all of modest size.

Things started to change in August, when federal regulators announced they were fining the Swiss bank UBS for failing to adequately monitor its customers’ foreign exchange transactions. The Treasury Department’s Financial Crimes Enforcement Network (FinCEN) called its $125 million penalty “historic,” noting it was the largest fine it had ever imposed on a broker-dealer.

Arguably, the amount should have been even higher, given that UBS was a repeat offender. In 2018 the company was fined $14.5 million for AML deficiencies. Moreover, in both cases the impact of the FinCEN penalties was substantially lessened when the agency agreed to reduce UBS’s payment obligation by the amounts it paid to other agencies for related cases. This year, that discount amounted to $48 million; in 2018 the reduction was $9.5 million.

The UBS case has now been overshadowed by FinCEN’s announcement that it is fining Bank of America $1.2 billion for violations of both AML regulations and economic sanctions laws. Treasury boasts that this is the third largest penalty in the department’s history. The Office of the Comptroller of the Currency, a branch of Treasury, also fined Bank of America $750 million, but that amount was deducted from the FinCEN penalty.

Bank of America’s case is not a purely AML matter. It focuses on the failure to report suspicious transactions said to be “indicative of Chinese Money Laundering Networks” and “trade-based money laundering with a substantial nexus to the southwest border.” It apparently was not enough for the AML deficiencies to involve the usual concerns of narcotics and terrorism. What may have been what got the White House to approve a rare crackdown on a major U.S. corporation was the link to Trump’s favorite issues of immigration and trade.

Along with the Bank of America case, the OCC and the Federal Reserve recently announced a $350 million penalty against American Express for what was called “systemic breakdowns in its suspicious activity monitoring and reporting processes, resulting in a failure to timely identify, evaluate, and sufficiently report approximately $13 billion of suspected trade-based money laundering activity that took place over the past decade.”

It is unclear whether the surge in AML enforcement is simply another way the Trump Administration is trying to sway voters in advance of the mid-term elections. Yet, such a ploy is unlikely to work. The DOJ and numerous federal regulatory agencies have already demonstrated their support for misbehaving companies by dropping investigations, abolishing regulations, and weakening enforcement. Even AI slop cannot conjure up a convincing image of Donald Trump as a corporate crime fighter.

Disaster Management

Rarely before has there been a time when the public discussion of large corporations is so focused on their potentially catastrophic impact on the human race. Say what you will about the tobacco industry, for instance, but no one ever suggested it threatened the survival of the species as a whole. Today such speculation is rampant when it comes to Big Tech’s creation of AI agents that may be beyond human control.

At the same time, Big Oil is facing a wave of lawsuits accusing it of bringing about a climate crisis that is threatening the lives of millions from excessive heat, drought, flooding, and other forms of extreme weather. In this case, the disasters are not speculative but all too real.

There is a troubling lack of consensus on how—or even whether—to hold the corporate giants accountable for the harms their products have caused and will cause. In the past, such harms were addressed in two main ways: regulation and private litigation.

Both of these tools are now in question. Depicting both rogue AI and the climate crisis as hoaxes, the Trump Administration is taking deregulation to absurd lengths. All federal controls on greenhouse gas emissions are being eliminated, and Trump has concluded that industry self-policing is all that is required for AI.

Oil companies, automakers, fossil-fuel-burning utilities, and other sectors are thrilled to be free from federal restraints. The AI giants, despite having issued calls not long ago for strong government intervention, now seem pleased to go along with Trump’s hands-off approach.

With serious regulation sidelined for now, it is unclear whether the courts can fill the accountability gap. This question is now being addressed in the Supreme Court, which just held oral arguments in a case that will determine whether states and localities can sue companies over climate issues. The Court already ruled in 2011 that federal common law nuisance claims were impermissible.

While the current case, which concerns a lawsuit brought by Boulder, Colorado against ExxonMobil and Suncor Energy, may end up focusing on technical issues of standing, the Justices are already paying attention to the bigger picture. They acknowledged that if the Boulder case is allowed to proceed, it will open the floodgates to many more such actions. Dozens have already been filed by state and local governments around the country.

There are two ways of looking at such a torrent. ExxonMobil et al. are, of course, seeking to prevent it by getting the Court to rule that federal law should govern or by convincing the Justices that the lawsuits would have dire economic consequences. In effect, they are arguing that the disaster that would befall them should be given more consideration than the disasters their decades of climate recklessness have brought about.

It is telling that the corporations don’t even consider the possibility they could prevail in the lawsuits. Instead of defending their position in the courts, they are seeking a form of impunity.

On the other hand, punishing lawsuits may be just what we need to address the harms caused by the fossil fuel industries.

Trump’s deregulatory crusade is bad news, but it will hopefully be reversed by the next administration. If the Supreme Court restricts climate litigation, that will endure for many years to come. It could also affect the viability of lawsuits against the AI companies.

Ideally, society should be able to rectify corporate misconduct both through regulatory enforcement and litigation. Losing both of these forms of redress would be a true disaster.

A Surprising Move by the CFPB

Most of the time, the Trump Administration’s Consumer Financial Protection Bureau appears to be a defunct agency. Yet, now and then, it stirs back to life.

This may happen when the administration wants to make it an even less effective regulator. For example, over the summer the CFPB announced that it was restricting the amount of detail included in the entries in its Consumer Complaint Database.

On the other hand, the bureau has just taken a step that would have been standard operating procedure in the pre-Trump era but which now seems totally out of character. It has filed a brief urging a federal appeals court to uphold a hefty enforcement judgment against the former operator of a defunct debt relief service.

The case involves Dean Tucci, who ran a company called FDATR, which promised struggling student loan borrowers that it could help them reduce their repayment obligations. In the waning days of the first Trump Administration, the CFPB sued Tucci and FDATR, accusing them of deceiving borrowers about what assistance they could provide.

Biden’s CFPB continued to pursue the case, but it remained unresolved when Trump returned to office. Tucci’s lawyers tried to convince the court to drop the case after Trump Treasury Secretary Scott Bessent became acting director of the bureau and ordered the agency to halt all work.

That ploy did not work. In May 2025 a federal court found Tucci guilty of violating the Telemarketing Sales Rule and the Consumer Financial Protection Act, imposing a civil monetary penalty and restitution totaling $43.2 million. By this time FDATR had been dissolved.

The tenacious Tucci is now appealing that ruling, perhaps hoping that the bureau, which has dropped numerous investigations, would not defend its case. Tucci may have thought that the new acting director, Mark Paoletta, might let the matter drop.

Surprisingly, the bureau submitted a brief to the appeals court that strikes back hard against Tucci, describing him as being “accountable for an unlawful scheme that tricked financially distressed consumers out of millions of dollars.” The brief goes on to say:

“At every step along the way, Tucci dragged his feet by (among other things) improperly refusing to participate in discovery and flouting his deadlines, including by ignoring his deadline to respond to the Bureau’s motion for summary judgment for nearly two years. After the district court was finally able to enter a final judgment in May 2025, Tucci prolonged the proceedings for another two months with post hoc objections that the district court rejected as frivolous. Now, Tucci has filed this appeal, in which he asks this Court to send this case all the way back to square one. Tucci’s request for a complete redo should be denied because none of the arguments scattered throughout his brief identifies any ground that would warrant reversing any ruling by the district court. Many of his arguments have been waived (some of them twice) or are otherwise untimely. All of them border on frivolous.”

This sort of no-nonsense filing is what is one expects from a regulator that is doing its job of enforcing the law. Yet is completely remarkable coming from an agency that for the past 20 months has been defunded, defanged, and used as a punching bag by the administration in its anti-regulatory crusade.

It is difficult to know what to make of the bureau’s position on the Tucci appeal. It may simply be the result of the bureau’s irritation at Tucci’s antics. Whatever the explanation, the brief serves as a reminder of how just about everything else the bureau is doing remains a betrayal of its traditional mission.

Another Assault on Democracy

Defenders of big business have long claimed that large publicly traded companies are democratic institutions, since shareholders are able to vote on issues of corporate policy. Activist groups, in turn, have used that avenue to press for changes in harmful practices.

This system, which has significant limitations, is set to become a lot less effective as the result of a rule change being proposed by the Securities and Exchange Commission. The SEC wants to eliminate Rule 14a-8, which would, in effect, free corporations of the obligation to include qualifying shareholder proposals in the proxy statements that are sent out in advance of annual meetings.

Paul Atkins, who was chosen by Trump to run the SEC, put out a statement disingenuously claiming the move is designed to ensure that “the Commission does not improperly intrude into state corporate law,” while failing to mention that this supposed intrusion has been in place since the 1940s.

By removing the SEC from consideration of shareholder resolutions, Atkins would leave it up to the states to oversee the process. Atkins knows full well that most large corporations are chartered in states such as Delaware that will adopt policies that would make it less likely that proposals will end up in proxy statements. Given the difficulties in publicizing proposals on their own, shareholder activists could very well give up on the effort.

Groups such as the Interfaith Center on Corporate Responsibility (ICCR) have been using the proposal process for decades. Often this does not involve an actual vote by shareholders, which in any event is not binding. Since managers would prefer that the vote never take place, activists can win concessions by agreeing to withdraw a resolution. The SEC’s proposal would likely eliminate that leverage.

The ICCR put out a statement questioning the legality of the proposed rule change and vowing to fight it. The big question is whether public pension funds and other institutional investors will take a strong stance on the issue. One encouraging sign: New York State Comptroller Thomas P. DiNapoli, trustee of the New York State Common Retirement Fund, issued a statement saying: “With this attempt to rescind Rule 14a-8, the SEC has chosen to allow corporate management to shield themselves from accountability rather than protect the investors it was created to serve. I will continue to fight to defend the NYS pension fund’s rights as a shareholder against these reckless attacks.”

Corporate America, on the other hand, is welcoming the move. The U.S. Chamber of Commerce praised the SEC, adding: “For too long, special interests have exploited Rule 14a-8 to advance their own agendas at the expense of public companies and their shareholders.” Leave it to the Chamber, the voice of some of the most powerful entities in the country, to pretend that it, and not the likes of ICCR, represents the public interest.

The elimination of Rule 14a-8 would not mean the complete disappearance of shareholder activism. Some states might adopt policies on resolutions that are not draconian, and there are tactics other than resolutions that activists can use to pressure management.

Yet the withering of the resolution process would represent another troubling step in the consolidation of corporate power.

What Are the AI Giants Really Up to?

There is something quite bizarre about the current debate on artificial intelligence. Never before have the heads of major corporations come out with warnings that their own products could threaten the future of the human race.

Such statements cannot be taken at face value. If Dario Amodei, Sam Altman, and Elon Musk believe those catastrophic possibilities to be literally true, they would be talking about dismantling AI, not simply slowing down its progression.

I’m not suggesting that the risks of AI are entirely fabricated, but the industry leaders seem to be using worst-case scenarios to try to throw us into a panic. The question is why.

One possibility is they are seeking to promote the idea that the dangers are so great that only they are qualified to handle them. This would be a bold new form of regulatory capture. The implied message is that only the geniuses who built AI are in a position to try to control it.

The AI barons may thus be setting the stage for a system of industry self-regulation that will not seriously inhibit their actions but give the impression they are addressing the risks. This would be similar to the mostly toothless measures adopted by social media companies in response to concerns about the harms to young people.

It is true that the AI leaders have made reference to government involvement, but it is likely they are doing so on the assumption that any such intervention will be less than robust or will not materialize at all. Donald Trump reinforced that supposition by immediately coming out in opposition to any new controls on AI, saying all that is needed is a “strong and smart (high IQ!) president.”

Another possibility is that the big AI companies are serious about wanting a slowdown, but they would seek to shape it so that it solidifies their dominant position by making it more difficult for competitors to emerge. The adoption of new guardrails on the technology would make it much more expensive to develop new AI products and thus price out upstart companies.

The AI industry may also be promoting cataclysmic thinking as a way of inoculating themselves against future legal liability. They could be assuming that by issuing their warnings now, they will be blamed less later when serious, but not quite extinction-level, consequences begin to materialize. We warned you, they may anticipate saying, and you failed to take appropriate action.

By offering up the worst possible scenarios, the industry may be seeking to numb people to the risks. Looking at what has happened with the climate crisis, they may be thinking that all the talk of catastrophe and human extinction will cause many to adopt a posture of hopelessness or indifference.

These theories of AI industry motivation may seem cynical, but it is difficult to believe that companies claiming to be capable of producing superintelligence are truly helpless to control their own creations.

Readers in DC may be interested to know that Michael Marx, author of Reining in the Bulls, the great new book on corporate campaigns I wrote about last month, will be appearing on October 1 at 6 PM at the Busboys and Poets at 450 K Street NW. The event will include a discussion on corporate accountability with Kathy Mulvey, Climate Accountability Campaign Director at the Union of Concerned Scientists. You can register here.

Regulators and the Anti-DEI Witch Hunt

During the second Trump Administration, many federal regulatory agencies seem to think their mission is to attack Donald Trump’s perceived enemies, often under the guise of investigating companies and other institutions for the purported crime of retaining practices seen as promoting diversity.

This category includes entities such as the Federal Communications Commission, whose attacks on ABC and its parent Walt Disney have been so egregious that the companies have gone to court to seek relief. It also includes the Equal Employment Opportunity Commission, which has turned its traditional mission on its head by treating measures to combat workplace bias as themselves discriminatory.

Also joining this group is the Securities and Exchange Commission, which has just gone to court to enforce a subpoena against Institutional Shareholder Services, claiming the proxy advisory firm is not cooperating with an investigation of its influence over institutional investor voting practices. ISS has responded by saying the subpoena raises serious First Amendment concerns while also saying that compliance could expose it and its clients to retaliation.

ISS has good reasons for these concerns. The SEC investigation seems to have been inspired by Trump’s executive order from last December attacking ISS and its rival Glass Lewis for providing “politicized advice.” The order called on the SEC as well as the Federal Trade Commission, to consider whether the proxy advisors are engaged in unfair, deceptive, or anti-competitive practices, which Trump has redefined to cover DEI and ESG.

The FTC has also reportedly been investigating ISS and Glass Lewis. In addition, the agency has used its antitrust authority to pursue an anti-DEI agenda. It has, for example, issued warning letters to dozens of major law firms warning that participation in a third-party diversity certification program could be a form of market manipulation and thus a violation of the Sherman Act.

Unlike some other agencies, the FTC has not completely abandoned its integrity. It has continued to pursue its mission of investigating actual corporate misconduct. And in doing so, it works closely with state attorneys general, who have taken on an increasingly important role as much federal enforcement has waned under Trump.

Recently, the FTC joined with 22 state AGs in filing suit against Amazon, alleging that the giant company engaged in deceptive and unfair practices that secretly inflated prices in its online search advertising auctions. In July, the FTC joined with Utah and California in bringing a lawsuit against the telehealth company Hims & Hers for allegedly sharing consumers’ sensitive health information with third-party advertising platforms despite promising patient privacy.

That same month, the FTC, along with five states, secured a settlement in an antitrust lawsuit against farm equipment manufacturer Deere & Company that ensured farmers can enjoy the right to repair their own John Deere tractors and farm equipment. Back in February, the FTC and 11 states got Walmart to agree to pay $100 million to resolve allegations that the company deceived delivery drivers about the base pay, incentive pay, and tips they could earn.

It may be too much to expect regulatory agencies to refuse to participate in Trump’s anti-DEI and anti-ESG witch hunts, but it is encouraging when they still find the time to carry out the kind of enforcement they were created to do.

The States Hold Meta to Account

The settlement between Meta Platforms and nearly all state governments to resolve litigation concerning the harms to young people caused by its social media apps is a landmark in corporate accountability. With a potential value of more than $17 billion, it is the second largest corporate penalty of the past 25 years, surpassed only by the $20.8 billion settlement paid by BP in 2015 in connection with the Deepwater Horizon oil catastrophe in the Gulf of Mexico.

It is by far the largest payout by a tech company, more than tripling the previous record of $5 billion paid by Meta itself in 2019 after the Federal Trade Commission found that it failed to comply with a 2012 order to stop deceiving users about their ability to control the privacy of personal information.

The new settlement brings Meta’s U.S. cumulative penalty total since 2000 to more than $25 billion, putting it in eighth place, just behind Volkswagen’s $26.2 billion total, which is linked largely to its emissions cheating scandal.

On the other hand, the amount being paid by Meta is only a fraction of the more than $100 billion Philip Morris has shelled out as its share of the massive settlement between the tobacco companies and the states in the late 1990s.

There is no question that Meta can easily afford to give up the $17 billion. This is a company, after all, that took in over $200 billion in revenue last year and currently has a market cap of $1.4 trillion. The deal is made more affordable by the fact that Meta’s payments will be spread out over a decade. The company also stands to lose a lot less than would be the case if the U.S. were to follow the lead of other countries and ban social media entirely for young people.

The question, as always, is whether a substantial penalty will get the company to change its practices. Fortunately, the settlement with the states is not purely monetary.

The agreement also requires Meta to make changes in its Instagram and Facebook services with the aim of discouraging compulsive use by young users. The company is supposed to re-program the apps to prevent minors from using them more than two hours a day and not at all after midnight. The limits are supposed to become stricter if operators of other platforms agree.

Among the other provisions are limits on notifications and the creation of an option for a non-personalized feed that doesn’t use an algorithm and thus doesn’t promote endlessly scrolling. The company is also required to give an independent auditor extensive access to internal data and will be subject to an injunction prohibiting it from making false, misleading, or deceptive statements about its safety features.

The settlement is unusual in that a substantial portion of the payout is contingent on Meta’s success in getting its main social media competitors to agree to similar restrictions and pay their own penalties. Meta was apparently willing to incur a larger legal liability if its platforms are not the only ones bound by the restrictions on under-age usage.

The Meta settlement may not completely eliminate the problem of social media addiction, but it shows how the states can join together to address a corporate abuse at a time when federal oversight is missing in action.

For Once a Corporation is in the Right

The Dirt Diggers Digest is normally in the business of cheering on regulators and prosecutors as they go after rogue corporations. I tend to be skeptical of claims of government overreach made by business apologists.

In the bizarro world created by the Trump Administration, I am at the moment forced to take a different stance. I find myself in the unfamiliar position of rooting for a major corporation in a dispute with a federal agency.

I am speaking, of course, about the conflict between the Walt Disney Company and the Federal Communications Commission. Disney and its American Broadcasting Company subsidiary have taken the unusual step of bringing suit to halt to an FCC process that threatens ABC’s broadcast licenses.

Like so much of what the Trump Administration does, the FCC’s move is based on a flimsy premise; namely, the claim that ABC has engaged in prohibited diversity practices. Trump and his administration’s officials like to bandy about the illegal DEI charge as if it had some solid basis in law. In fact, it derives solely from dubious executive orders issued by Trump asserting that any policies designed to remedy discrimination are themselves discriminatory.

The argument is especially problematic when it comes to the FCC. Back in the 1960s, public interest groups pressured the agency to adopt policies to combat discrimination and promote diversity in the communications industry. The policies required broadcasters to take positive steps to promote the hiring and promotion of minorities and women.

The FCC’s MAGA-friendly chairman Brendan Carr may not be aware that his agency’s website still has a page on equal employment rules and policies that includes the following statement: “The EEO rules require broadcasters employing five or more full-time employees, and MVPDs [multichannel video programming distributors] employing six or more full-time employees, to maintain an EEO recruitment program. The recruitment rules include requirements to provide notice of job vacancies and to undertake additional outreach measures to all qualified job candidates, such as holding job fairs and establishing scholarship programs.” That sure sounds like DEI.

Apart from the FCC’s hypocrisy, there is the fact that Disney has already been reversing many of its diversity initiatives and has removed references to DEI from its SEC filings.

In short, Disney is well justified in arguing that the FCC’s unorthodox review of ABC’s licenses has little to do with DEI and is, instead, part of Trump’s vendetta against what he views as unfriendly news media outlets. Disney’s lawyers did not have to work very hard to make their case. In their court filing, they quoted various statements from Trump himself calling for the revocation of licenses of  such outlets.

None of this is to claim that Disney is a paragon of corporate virtue. The company has a problematic history when it comes to labor practices at its theme parks and in the foreign sweatshops that produced its merchandise.

It has also faced charges of discrimination, and last year it agreed to pay $43 million to settle class action litigation alleging it paid thousands of women in middle management less than their male counterparts But such serious discrimination is not what the FCC is targeting.

As long as this regulator is helping to carry out Trump’s grievance campaign, it does not deserve support from those of us concerned about corporate accountability.

How To Confront Corporate Abuses

Amid the endless threats to democracy and social well-being posed by the Trump Administration, less attention may be given to the more enduring harms created by the powerful corporations that control so much of our life. A valuable reminder of the importance of confronting those business behemoths can be found in a new book by Michael Marx called Reining in the Bulls: How to Stop Corporate Abuses in an Age of Unbridled Greed.

Marx has produced the first comprehensive guide to what are known as corporate campaigns: efforts by environmental groups and other civil society organizations to pressure companies to alter specific detrimental practices. They are also called pressure campaigns, market campaigns, or anti-corporate campaigns. Examples include the Greenpeace effort to get Nestle to stop using palm oil linked to rainforest destruction in Indonesia and the campaign by the Natural Resources Defense Council and U.S. PIRG to get Columbia Sportswear to eliminate toxic PFAS forever chemicals from its products.

The “how to” in Marx’s subtitle should be taken literally. His book provides detailed tips on every aspect of a corporate campaign—from documenting the harm and choosing the target company to the choice of tactics, recruitment of allies, fundraising, and much more. For those situations in which companies bend to the pressure, he offers advice on negotiating agreements that will institutionalize the victory. For those in which the company resists, he offers guidance on dealing with the counterattack. (Full disclosure: in his chapter on power-mapping the target company, Marx makes a brief complimentary reference to my Dirt Diggers Digest research guide.)

Marx is well qualified for this task. For the past 30 years, he has worked on corporate campaigns with groups such as Rainforest Action Network, ForestEthics (now Stand.earth), and the Sierra Club. He founded Corporate Ethics International, which gave rise to the Business Ethics Network, a sort of trade association for corporate campaign groups.

Like all good handbooks, Reining in the Bulls is full of lists such as the Corporate Ethics Ten Commandments and the Typical Stages of a Corporate Campaign. There are various step-by-step guides to campaign elements, including shareholder advocacy, recruitment of corporate insiders, and mobilization of actions both online and in the streets. There is even a chapter on the challenges (and rewards) of devoting one’s life to corporate campaigns.

Despite all this valuable content, there are a couple of gaps. First, I would have liked to see more attention paid to corporate campaigns mounted by labor unions. In his preface, Marx mentions the path-breaking role of the campaign against J.P. Stevens conducted by the Amalgamated Clothing and Textile Workers Union in the 1970s, and he notes a few others such as the Steelworkers campaign against Ravenswood Aluminum in the 1990s. Yet, for the rest of the book, unions are pretty much ignored, even though Marx has a whole chapter on organizing employees of target companies. The chapter on organizing shareholders does not discuss the important work done by activist union pension funds.

It would also have been helpful to have more content oriented to grassroots corporate campaigns. Marx focuses on efforts launched by groups with significant resources, including paid staff, foundation funding, and a robust online presence. It thus makes sense that he recommends, for instance, that organizations carry liability insurance and pay to obtain targeted mailing lists.

But what about groups that are operating on a shoestring? They are the ones that need the most help in conducting their campaigns. Much of Marx’s guidance will serve them well, but they have many additional challenges.

Addressing those challenges is all the more urgent, given that the most vibrant form of corporate campaigning seen today are the grassroots groups that have sprung up across the country to fight against the explosion of data center construction in support of the AI mania. They need all the help they can get.

That said, I hope Marx’s book inspires more people to take up the noble cause of confronting corporate abuses of all kinds.