Why do you think it's any of the employees that are at fault, even the c-levels?
Fine the investors. Everyone who owned a share when the violation occurred takes a lick.
If you go after c-levels, what will happen is they'll devise some sort of time deferred compensation avoids the penalties you want to impose. The board needs a CEO after all, and CEOs are reluctant to run a company if they know they'll just have their paycheck confiscated.
I mean that's effectively already how it works: a fine to the company is a fine to the investors, because they own the company (more precisely, a fine represents money which is not getting paid back). And clearly that isn't enough, because this stuff keeps happening, that's why the GP and others are brainstorming alternatives.
A fine to the company just eats away a little of the profit. Maybe the dividend is lower next year.
A fine to the investor is literally taking money out of their pocket. Before they receive the dividend check. Even if it nets the same to them in the long run, it will feel different. It will be true punishment rather than reduced reward at a later date.
Fine the investors. Everyone who owned a share when the violation occurred takes a lick.
If you go after c-levels, what will happen is they'll devise some sort of time deferred compensation avoids the penalties you want to impose. The board needs a CEO after all, and CEOs are reluctant to run a company if they know they'll just have their paycheck confiscated.