Purpose of this Guide

As corporations face increased regulatory, shareholder and public scrutiny, it is essential that they be able to investigate evidence or allegations of corporate wrongdoing at an early stage. Allegations of “white-collar” crime can arise from several sources including external or internal auditors or whistleblowers, regulators, or the media. Corporations (and their legal advisors) may find it necessary to conduct an internal investigation and take appropriate action to limit their exposure to criminal, regulatory and civil actions.

This Guide discusses best practices to conduct an internal investigation into allegations of bribery, corruption and other white-collar crimes. While it is not a definitive legal treatise, it offers guidance on:

• Circumstances that may require an internal investigation
• Cooperating with enforcement agencies
• Maintaining and waiving solicitor-client privilege
• Independence of the investigation counsel
• Document preservation, collection and review
• Witness interviews (and employee witnesses)
• Multi-jurisdiction investigations