Reimagining Governance Structures in Family Offices
Explore innovative governance structures in family offices to enhance decision-making and engagement among stakeholders.

Sometimes uncovering a massive financial fraud doesn’t require a team of forensic accountants, sophisticated artificial intelligence or months of detective work. Sometimes it starts with one sentence.
Several years ago, I was contacted by a West Palm Beach company called Wells Real Estate Investment. The company presented itself as a substantial real estate investment operation and represented that it controlled a real estate portfolio worth hundreds of millions of dollars.
I agreed to meet with them.
I sat down with a team of approximately six people for what became roughly a two-hour meeting. On the surface, it looked like many other meetings I have had during my decades working in the hedge fund and family office industries.
Then I asked a very ordinary business question: Who should our agreements be with?
Jean “Jon” Joseph gave me an extraordinary answer:
Don’t ever put anything in my name.
— Jean “Jon” Joseph
That was the moment everything changed.
In my experience, when someone involved in running an investment operation specifically tells you not to put his name on anything, you find out why.

So I did something remarkably sophisticated.
I Googled him.
What I found immediately concerned me. Joseph had a previous federal fraud conviction and had served prison time.
I couldn’t understand how someone with that history could apparently be involved behind the scenes of an investment operation raising millions of dollars from the public.
That question started me down a path that would eventually intersect with what federal authorities described as a massive real estate investment fraud involving more than $50 million and hundreds of victims.
But at the time, I didn’t have the benefit of an SEC complaint, a Department of Justice prosecution or a court-appointed receiver.
I had one suspicious statement and a lot of questions.
The subsequent government cases were staggering.
The Securities and Exchange Commission alleged that Wells Real Estate Investment raised at least $56 million from approximately 660 investors.
Investors were allegedly told that their money would primarily be used to purchase and improve income-producing real estate.
According to federal authorities, however, tens of millions of dollars were diverted elsewhere.
Approximately $28 million was transferred into brokerage accounts for speculative trading in securities, including futures and options. Millions were lost.
Millions more were used to make payments to earlier investors — the classic characteristic that causes authorities to describe an operation as Ponzi-like.
Millions of dollars were also paid in sales commissions.
And federal prosecutors ultimately alleged that personal expenses were paid with investor money as well.
Perhaps one of the most extraordinary representations concerned the size of Wells’ supposed real estate holdings.
Investors were led to believe Wells controlled a real estate portfolio worth as much as approximately $450 million.
Federal authorities painted a dramatically different picture.
There was another remarkable element.
Joseph wasn’t simply someone with an old criminal conviction.
Federal prosecutors subsequently said that Joseph continued directing aspects of Wells while serving a federal prison sentence for an unrelated fraud case.
Think about that for a moment.
A man already imprisoned in connection with fraud was allegedly helping direct an investment operation that was raising tens of millions of dollars from investors.
Joseph eventually pleaded guilty in the Wells-related criminal case.
In August 2026, a federal judge sentenced him to 20 years in prison.
Janalie Bingham, Wells’ CEO and Joseph’s wife, pleaded guilty to wire fraud and received a four-year federal prison sentence.
But to me, the Wells story is about much more than two individuals.
It exposes a potentially much larger weakness in the rapidly growing family office industry.
One of the most important organizations in the Wells story was called Sanders Family Office.
The name alone would give many investors an immediate impression.
“Family office” has become one of the most powerful phrases in the wealth-management industry. It suggests enormous private wealth, sophisticated investors, professional due diligence and access to opportunities unavailable to ordinary investors.
In 2026, the SEC brought an enforcement action against Sanders Family Office LLC and Margaret Sanders relating to their activities involving Wells.
According to the SEC, Sanders and Sanders Family Office, directly and through a network of salespeople, helped raise approximately $40 million from roughly 600 Wells investors.
That’s an extraordinary percentage of the money involved.
The SEC alleged that Sanders and her firm received approximately $3 million in transaction-based compensation while neither Sanders nor Sanders Family Office was registered with the SEC as a broker-dealer or associated with a registered broker-dealer.
Sanders and the company settled the SEC action without admitting or denying the allegations.
This is where the Wells story becomes bigger than Wells.
There is tremendous confusion surrounding the term “family office.”

Under the SEC’s family-office exclusion from the Investment Advisers Act, a qualifying family office generally must provide investment advice only to “family clients,” be wholly owned by family clients and exclusively controlled by family members or family entities, and not hold itself out to the public as an investment adviser.
That is very different from using the words “family office” in a company name.
And the family-office exclusion certainly isn’t a blanket exemption from securities laws.
Calling an organization a family office does not automatically permit it to solicit outside investors, sell securities, receive transaction-based compensation or perform activities that otherwise require registration.
That distinction is enormously important.
For years, I have warned about what I call the FFO — the Fake Family Office.
These are organizations that use the prestige of the family-office label even though their actual businesses may bear little resemblance to a traditional single-family office managing the wealth and affairs of one family.
The danger isn’t simply semantic.
Imagine you’re an investor and someone tells you:
“We’re a family office.”
Your perception of that organization can change immediately.
Those assumptions can be dangerously wrong.
The Wells case demonstrates why investors need to look beyond labels.
My involvement didn’t end when I discovered Joseph’s history.
Within a few days, an employee connected to the operation contacted me. He knew about my reputation for integrity, and we arranged to meet.
What he shared with me was among the most disturbing and extraordinary information I had heard in 30 years in the industry.
That same day, I contacted my securities law firm and shared everything he had told me. The firm immediately began the process of formally representing him as a whistleblower.
He provided photographs, documents and substantial additional information that helped illuminate how the operation worked from the inside.
The information was not limited to the investment structure. It also raised questions about the company’s recruiting practices, its marketing strategy and the public figures and institutions it used to create an appearance of legitimacy.
For more than a year, I allowed the whistleblower to live in my home. I did so because I believed he needed protection and stability after coming forward. Some experts describe individuals involved in this type of conduct as sociopathic, and I understood that the risks to someone who speaks out can be serious.
Because we acted quickly, I sincerely hope that our efforts helped prevent additional people from becoming victims.
Here are some of the insights the whistleblower shared with us.
The hiring process reportedly included the question:
Sell me this pen.
That may sound like a standard sales interview exercise. But in this context, it raised questions about whether the organization was prioritizing aggressive selling ability over investment experience, compliance knowledge or fiduciary responsibility.
According to the whistleblower, many employees came from the Midwest and had relatively limited experience in the investment industry.
That fact alone proves nothing. But when inexperienced employees are placed in a high-pressure sales environment involving complex investments, the risk of misleading statements, inadequate due diligence and poor investor understanding can increase substantially.
The whistleblower also described the company’s use of three Palm Beach County mayors in its efforts to establish credibility.
All three mayors were Democrats.
We have documentation relating to these relationships and intend to present the evidence supporting these claims. The broader question is why public officials, regardless of political affiliation, would be associated with an investment operation that was allegedly raising tens of millions of dollars from investors.

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