Internal Investigations

Corporate clients often retain us to conduct sensitive and discreet internal investigations aimed at uncovering or resolving allegations of misconduct. Knowledge or suspicion of criminal conduct within an organization may surface before or after the government commences an investigation. The existence of grand jury subpoenas; the simple allegations of employees, customers, or competitors; the results of a compliance or internal audit—all may point to criminal conduct within an organization. In such cases, a candid and complete assessment of the scope and nature of the conduct and consideration of self-disclosure of wrongdoing to the government are essential to limit the organization’s criminal exposure.

We have conducted independent internal investigations on behalf of audit committees and other special committees investigating allegations of accounting fraud, health care fraud, potential violations of the Foreign Corrupt Practices Act, customs violations, environmental crimes, and financial improprieties. Our investigations give our clients the tools to understand what has taken place and to decide upon appropriate courses of action, such as whether and how to voluntarily disclose criminal conduct to the government, whether to discipline those responsible, whether to waive or retain the attorney-client privilege with respect to the matters investigated, how to conduct interviews of management and employees, how to treat whistleblowers and cooperating witnesses, how to document and report on the results of the investigation, and how to implement measures to prevent recurrence of any wrongful conduct.