All Investigations articles

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    The Board of Directors needs an answer before the current reporting period ends. Furtive harassment needs to be uncovered and countermanded immediately. A regulatory agency needs immediate assurance that internal procedures will suffice, otherwise a compliance investigation will be initiated. The CEO needs to know whether terms of the M&A ...

  • Article

    Don’t be caught unprepared for a ‘dawn raid’


    Unannounced inspections have become a fearsome weapon for regulators in Europe, so you need to know what to do in case your company ends up being a target.

  • Article

    Workplace investigations: 8 pitfalls to avoid


    Investigating workplace complaints of harassment, intimidation, and other interpersonal issues is as challenging as it is mandatory. Sahil Kanuga shares eight common pitfalls to avoid.

  • Article

    Longer case closure times boost risk of whistleblowers reporting externally


    Employers are taking longer and longer to act on internal whistleblower reports, which can frustrate employees who have been encouraged to step up and report what they see as unacceptable behavior. As reporters find their concerns languishing in limbo, the chances they might simply take their issue to an outside ...

  • Article

    Employee Investigations Post-Yates Memo


    Image: Any company that has faced allegations of corporate misconduct knows how quickly the scope and cost of an internal investigation can grow—a concern that has only amplified following the Justice Department’s Yates Memo. “Corporate compliance professionals have expressed concern that this policy will result in companies undertaking unnecessarily broad, ...

  • Blog

    Leniency in Petrobras Scandal Means Decision on Self-Disclosure


    As the Petrobras corruption scandal moves to the investigation of international companies that did business with the Brazilian national energy company, Europeans companies now face some challenging decisions around the issue of self disclosure. Our Man From FCPA, Tom Fox, has more inside about the considerations you need to make.

  • Article

    Global Investigations in the Modern Era


    “Europe” may be a nice short-hand for discussions about global business, but in reality is still 28 individual nations, each with their own laws and customs. Little surprise, then, that in several discussions about internal investigations at the Compliance Week Europe conference, the subject got complicated quickly. We have the ...

  • Article

    When a Board Member Goes Bad


    Image: Investigations into rumors of misconduct are part of a compliance officer’s job. Seldom, however, is the task as delicate as when investigating a board member. “You need to think about making decisions knowing that the facts may end up completely different, once it is all done,” Adam Frankel, general ...

  • Article

    Navigating Global Internal Investigations Under Main Justice’s New Policy


    Image: The Justice Department’s new Yates Memo, demanding much more cooperation from companies to find individual wrongdoers, will pressure companies to pressure employees during internal investigations. In Europe and elsewhere, however, the law favors employees much more than in the United States, making global investigations a tall order. “Most developed ...

  • Blog

    The FCPA Enforcement World Changed Last Week


    Image: The Yates Memo issued by the Justice Department last week, insisting that companies work much harder to help prosecute individuals if they want to receive cooperation credit, is likely to be a sea change in how compliance officers must address problems like Foreign Corrupt Practices Act investigations. Our FCPA ...

  • Article

    Post-Investigation Follow-Up and Discipline at 3M


    Image: What role should compliance officers have in investigations and discipline? How can they maintain independence during an investigation and subsequent sanctions decisions, while developing an effective strategy for what happens next? We talked to Jim Zappa, chief compliance officer at 3M Corp. about his approach. Zappa will be among ...

  • Blog

    Hertz Restatement Expands, May Involve Tone at the Top; SEC Investigating


    Hertz’s single-year restatement announcement in June has mushroomed into a multi-year restatement and an investigation by the Securities and Exchange Commission, the company reported on Friday in a Form 8-K filing. The filing offered the first hints that the problems may stem from poor tone at the top. More ...