Once you have discovered that your company is the subject of an anti-corruption investigation – either one prompted internally or by the government – an investigation plan must be formulated and effectuated. How can your company marshal resources most efficiently to ensure a thorough investigation? What are the best methods for conducting interviews and collecting documents? What should the company do in response to any issues identified by the investigation, and what collateral consequences should it be prepared to deal with? While no two anti-corruption investigations are the same, this two-part guest article series written by Mara V.J. Senn and Michelle K. Albert, partner and associate, respectively, at Arnold & Porter LLP, walks through the anatomy of a typical investigation and identifies key considerations and best practices at each stage to aid both in-house and outside counsel. This, the second article in the series, discusses, among other things, developing an investigative plan, strategies for witness interviews and document collection, ten best practices for cross-border investigations, managing the self-reporting calculus and handling remediation and other concerns at the end of the investigation. The first article
detailed typical triggers for investigations and explained ten crucial factors that a company should consider at the start of the investigation.