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Stealing from Colleagues? Fraud and Embezzlement in 401(k) Plans
Fisher Broyles via Lexology; registration required 
May 15, 2019
"Do not underestimate the creativity of insiders who have no compunction about helping themselves to money others have saved and invested. Employers/clients (and their ERISA advisers) should educate and train themselves as to nature of embezzlement and fraud, as well as the modes of commission (means, opportunity, and motive for embezzlement and fraud), particularly where a plan's internal controls and organizational framework may be less than optimal."
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