Photo: Rick Kopstein/ALM penalty Julie Myers Wood nonprosecution agreement order
  • Training for all employees to report such misconduct when they see it, or at least to flag suspicious activity, such as unqualified hires, to legal and compliance departments.
  • An internal review of hires on a spot basis by legal or compliance.
  • A quality assurance program in the human resources department on both hires and applications that are in the pipeline to make sure the employee is qualified for the job.
  • Consequences to an employee for misconduct.
Cahill Gordon & Reindel