Former Prosecutor Nathaniel Edmonds Shares His Internal Anti-Corruption Investigation Strategies

At the first sign of a red flag that points to possible bribery, a multi-national company must consider whether to initiate an internal investigation, which can deter any nefarious activity, demonstrate an independent commitment to good compliance, and if the wrongdoing has already occurred, prevent or mitigate any potential charges.  However, if not conducted properly, internal investigations can present their own risks, including inadvertent disclosure of the investigation, waiver of the attorney-client privilege, and accusations of improper handling or even obstruction of justice.  To mitigate these risks, a company should adopt a carefully-conceived plan for conducting internal investigations.  In an interview with The FCPA Report, Nathaniel Edmonds, a partner at Paul Hastings and a former FCPA prosecutor, discusses best practices for preparing for, conducting and concluding an investigation, including the appropriate way to handle data, and reveals the biggest mistakes he has witnessed companies make during the investigative process.  See also “How to Handle a Government Investigation: Insight from PwC, Covington, Booz Allen and FINRA,” The FCPA Report, Vol. 3, No. 21 (Oct. 22, 2014). 

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