Are you saying Dave is in possession of the financials and refuse to hand it over to the CFO, so she can do her job and get us back into compliance? What proof you have of this?
Maybe Dave is doing the financials himself and when completed he will hand it over.
If that is not the case, and he distrust the others, all he has to do is copy the records, do his own financials, get it audited and compare it with the CFO accounting and the company's independent auditors result.
He cannot allege fraud unless it is audited and reveal so.
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