OAKLAND — Megan Hall-Greenberg, 49, and Jeffrery Greenberg, 45, of Washougal, Washington, and Heather Morgan, 47, of Camas, Washington, have been charged by indictment with wire fraud and conspiracy to commit wire fraud, alleged to have conspired to misappropriate millions of dollars of funds from Surro Connections. Hall-Greenberg and Greenberg were also charged with money laundering and conspiracy to commit money laundering.
As part of the scheme, the defendants are alleged to have concealed the misappropriation from Surro Connections’ clients, the intended parents and the surrogates. Surro Connections collected and held funds, often totaling over $100,000 per client, that were pledged to be used to cover the costs of surrogacies, including legal fees, medical costs, compensation to surrogates, travel, and other costs.
Instead, as alleged in the indictment, Hall-Greenberg and…
MANAGEMENT & CULTURE (THE “TONE AT THE TOP”)
Fraud thrives in “sloppy” environments where leadership ignores the rules.
- The Fraud Triangle: For fraud to occur, three elements must be present: Pressure (the need for money), Rationalization (thinking “I deserve this”), and Opportunity (weak controls). You can only control the Opportunity.
- Whistleblower Hotline: Provide an anonymous way for staff to report “odd behavior.” Most internal frauds are caught via tips, not audits.
- Background Checks: Conduct credit and criminal record checks for all employees in financial or data-sensitive roles.
- Annual Ethics Training: Make sure every staff member knows that the company has a Zero Tolerance policy toward “borrowing” from petty cash or fudging overtime.