August-October 2012 (Reprinted in Corporate Governance Advisor, November/December 2012; Reprinted in Bloomberg BNA, White Collar Crime Report, August-October, 2012)

Corporate Internal Investigations: A User Guide for Companies (Three-Part Series)

The Corporate Counselor
Vito A. Costanzo | Stacey H. Wang

Companies are under increasing pressure to investigate and self-report allegations of corporate misconduct. As government agencies become more aggressive in investigating allegations of corporate fraud and abuse, an unprepared company may unwittingly find itself mired in obstruction of justice charges because initial protective steps were not taken to identify and preserve potential sources of evidence and to establish the independence of the company’s decision-makers vis-à-vis the alleged misconduct.

This three-part series provides companies with a step-by-step guide for planning and conducting sensitive internal investigations into potential wrongdoing.

Part one of the series discusses the initial decision of whether to conduct an internal investigation and immediate steps that must be taken to preserve evidence and create an independent investigation.

READPart One

Part two addresses how to design and plan internal investigations, including how to define and charter the investigation and document collection and review.

READ: Part Two

The last installment of the series covers witness interviews, memorializing findings, whether to self-report violations, handling whistleblowers and pre-investigation preparation.

READPart Three

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