A Quick Lesson on Enhanced Due Diligence from Moderna's CFO Firing

2 Minutes Read

Jorge Gomez's departure from Moderna is a cautionary tale for hiring and compliance professional

The high-profile ousting of Moderna's new CFO Jorge Gomez, after just one day on the job highlights the importance of in-depth background investigation or enhanced due diligence when hiring c-suite level executives. In today's business climate, it is more important than ever to ensure that the individuals you entrust with leading your company are of the highest calibre and beyond reproach.

Although investigations into Mr Gomez's conduct were launched back in March 2022, Moderna claims it was unaware of them until the end of May. This begs the question: how thorough was Moderna's due diligence process in vetting Mr Gomez before extending him an offer of employment?


Essential note for the compliance and hiring managers

Companies simply cannot afford to take shortcuts in the due diligence process when hiring c-suite executives. These individuals are entrusted with not only the company's day-to-day operations but also its long-term strategy and vision. As such, they must be thoroughly vetted to ensure that they are not only qualified for the job but also have a solid track record of ethical and compliant behaviour.

Compliance and hiring managers are vital in ensuring that due diligence is conducted properly when hiring c-suite executives. In addition to reviewing resumes and conducting reference checks, compliance and hiring managers must also be on the lookout for any red flags that could indicate a potential problem.

For example, does the candidate have a history of employment litigation or disciplinary action? Have there been any concerning allegations made against the individual in the press or on social media?

Answering these questions can help compliance and hiring managers to weed out problematic candidates before they are hired—and help prevent disasters like what happened at Moderna from occurring in the first place.


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The need for in-depth background investigation or enhanced due diligence for the high-profile position

Many companies rely on standard background checks to vet their employees, but this type of check is often insufficient, especially when hiring for C-suite positions. Standard background checks usually only verify four or five elements, such as education and criminal history.

This fails to capture a large amount of detail about the person in question and is also unsuccessful at taking a comprehensive look into an executive's involvement in other business entities, lawsuits, reputation, behavioural history and other risk exposures.

When hiring executives and board members, conducting an in-depth background investigation or enhanced due diligence is significant. It is a tier 3 due diligence process that looks at more than 25 types of public records and open-source intelligence, including highly specialised intelligence and deep web searches. This is combined with an in-depth review of media and news sources.

Enhanced due diligence can uncover many issues that would not be found in standard background checks, including alias names, con artists and fraudsters, misrepresentation and misconduct at previous jobs, damaged business reputation, SEC violations, breach of contract history, history of sexual harassment, fraud, money laundering, embezzlement, bribery, interstate bankruptcy, intellectual property theft, manslaughter and murder.

Conducting due diligence is essential for ensuring that you are hiring the best possible candidates for your organisation.


Precautious Step

This story is a cautionary tale for compliance and hiring managers who are responsible for conducting due diligence on prospective employees. In order to avoid potential reputational damage (not to mention legal ramifications), it is critical that companies take a closer look at an applicant's background extensively before extending an offer of employment.

While we don't know the full extent of Jorge Gomez's involvement in the investigation at Dentsply, his short tenure at Moderna serves as a reminder that employee risks should be taken seriously. Organisations should consider conducting regular background checks on all employees, especially those in senior positions.




Picture of Nurul Damia

Nurul Damia

Nurul is a digital advocate for Corporate Research and Investigations (CRI® Group) and ABAC® Center of Excellence. She assists the advocacy work of CRI Group and ABAC on omnichannel platforms on anti-bribery, anti-corruption, compliance and risk management, anti-fraud, background screening, due diligence and third-party risk management.