The Association of Certified Fraud Examiners (ACFE) conducts fraud prevention training for U.S. businesses. Training focus is both internal and external—preventing fraud against the business as well as fraud by company employees against others.

An important standard taught is the tone set for ethical integrity leadership:

An organization’s leadership creates the tone at the top – an ethical (or unethical) atmosphere in the workplace. Management’s tone has a trickle-down effect on employees. If top managers uphold ethics and integrity so will employees. But if upper management appears unconcerned with ethics and focuses solely on the bottom line, employees will be more prone to commit fraud and feel that ethical conduct isn’t a priority. In short, employees will follow the examples of their bosses.

Obviously, the larger an organization, the more difficult to hold all within it accountable to this standard. However, when numerous examples of a lapse in an organization’s ethical conduct exist, the tone set at the top comes into question.

Next week, a five-month long investigative report will be released finding U.S. Central Command intelligence ISIS and al-Qaeda threat assessments were intentionally downplayed. While offering no definitive evidence President Barack Obama ordered it, determining whether he did or not creates a need to look at the tone set for truth-telling.

Recently, the U.S. Department of Justice (DOJ) ordered more ethics training for its attorneys based on a judge’s findings he was misled by DOJ lawyers in a high-profile lawsuit initiated by 26 states opposed to Obama’s immigration policies.

Apologizing for any confusion, DOJ lawyers deny making intentional misstatements. But their soft-pedaling contrasts significantly with the judge’s finding, “The misconduct in this case was intentional, serious and material.”

A recent Hillary Clinton email release suggests DOJ may also have blocked a Clinton Foundation probe.

For those believing it unfair to pin transgressions of one wayward federal agency as an indictment of the president under whom it serves, let us turn to Obama’s executive branch staff—where he held the most direct influence.

Ben Rhodes is Obama’s foreign policy guru. He is credited with setting the tone for the Iran nuclear deal both via his interactions with the press and Congress. Throughout the process, he maintained a low profile.

However, with the deal concluded, it has been difficult for Rhodes to contain his successful deception of the media and Congress. In a New York Times interview, he boasted about doing exactly that. And, anyone who knows Rhodes, knows he and Obama enjoy a mind-meld mentality.

For Obama defenders still believing DOJ misconduct and one self-admitted lying foreign policy guru do not an unethical president make, we continue.

Concerning the Iran nuclear deal, Secretary of State John Kerry attempted to deceive Congress there were no side deals. We now know there were at least three.

As reported by the Associated Press, under one side deal, restrictions imposed by the known agreement “will ease in slightly more than a decade” rather than the 15 years originally claimed, thus reducing “the time Tehran would need to build a bomb to six months from the present estimates of one year.”

An aspect of the Iran deal making more recent headlines is the $400 million cash payment to Iran—sold to Congress at the time as a release of “Iranian” funds. Disclosures now suggest the fund release was actually a devious way for Obama to pay a ransom for Americans the mullahs held hostage. Senior DOJ officials objecting to the payment were overruled by Kerry. Obama continues to deny it was ransom money despite evidence strongly suggesting Tehran viewed it as such.

Meanwhile, Hillary Clinton’s vice presidential running mate, Senator Tim Kaine, also denying it was ransom, claims, “We don’t pay for hostages. We don’t negotiate for hostages, absolutely not. We’re a nation of laws…” Yet, the White House, admits some of the money paid Iran could go to fund terrorism—a clear violation of U.S. laws.

Tehran even boasts about Obama’s efforts to deceive Americans on the nuclear deal. The Iranians were told not to discuss their missile tests, conducting them in secret so as not to draw attention to a flawed deal.

Evidence has also come to light that the U.S. State Department manipulated data given to Congress, downplaying anti-Israel bias charges against the UN Human Rights Council.

But, enough about State Department lies. Let us now turn to other federal agencies.

The Federal Bureau of Investigation (FBI) confirmed this month the Internal Revenue Service (IRS) had inappropriately targeted tea party and other conservative groups seeking non-profit status. As IRS targeting became an issue, it tried blaming it on “rogue agents.” However, internal documents reveal the tone was set at the agency’s top level.

Director of National Intelligence James R. Clapper also suffered effects of the tone. In June 2013, he apologized to the Senate Intelligence Committee chairman for lying during a hearing. He had responded “No,” when asked specifically if NSA was spying on Americans. Only after Edward Snowden leaked classified documents revealing secretive U.S. government programs monitoring hundreds of millions of Americans did Clapper’s lie come to light.

The tone from the top includes misrepresenting facts tied to our national security and Muslim immigration.

The Senate Judiciary Committee determined in June 2016 the number of refugees arrested for terror in the U.S. was more than three times higher than what State Department reported.

Additionally, concerning criminal aliens in general, it was determined the number reported by Immigration and Customs Enforcement as released in 2014 who then went on to commit additional crimes was under-reported to the House Judiciary Committee by almost 90 percent. This led Committee Chairman Bob Goodlatte to say Obama was creating “a sanctuary for tens of thousands of criminal aliens.”

The Secret Service also fell victim to Obama’s unethical tone, releasing a congressman’s personnel file in retribution for his disclosures about agent misconduct.

Obama’s unethical leadership has had a trickle-down effect. While 42 years ago such leadership caught up to a U.S. president, it appears Obama, inexplicably, will be spared a similar fate.

Lt. Colonel James G. Zumwalt, USMC (Ret.), is a retired Marine infantry officer who served in the Vietnam war, the U.S. invasion of Panama and the first Gulf war. He is the author of “Bare Feet, Iron Will–Stories from the Other Side of Vietnam’s Battlefields,” “Living the Juche Lie: North Korea’s Kim Dynasty” and “Doomsday: Iran–The Clock is Ticking.” He frequently writes on foreign policy and defense issues.