Jeffrey Tenenbaum, head of the nonprofit practice at the DC-based law firm Lewis Baach Kaufmann Middlemiss PLLC, appeared on NPR Affiliate WOSU Public Media to discuss the steps nonprofits can take to prevent the type of misappropriation alleged in the Jeffrey Epstein case.
Tenenbaum says he does not know the details of the Wexner-Epstein arrangement and cannot comment on it directly, but that there are measures nonprofits can take to avoid misappropriation.
“Here in this particular case involving Wexner and Epstein, it certainly seems like none of these steps were taken," Tenenbaum says. "Things like requiring double signatures, double authorization, back up documentation before funds can be paid or transferred, segregation of duties amongst employees, doing inventories of your fixed assets."
He also says Wexner could have set up electronic alerts so he knew every time a payment or transfer was made.
"Making sure that everyone in the finance and accounting department is required to take a certain length of vacation each year, at least two weeks, to see if that person is involved in a fraud,” Tenenbaum adds. “Because if that person's gone and someone else is assuming his or her duties, it gives you a chance to spot what's going on."
NPR Affiliate WOSU Public Media