How to Conduct an Anti-Corruption Investigation: Ten Factors to Consider at the Outset (Part One of Two)

What should you do when a subpoena arrives on your desk, asking about suspected bribe payments to foreign officials?  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.  The first article details typical triggers for investigations and explains ten crucial factors that a company should consider at the start of the investigation.  The second article in the series will discuss, among other things, formulating an investigative plan, best practices for cross-border investigations, the self-reporting calculus and concerns collateral to the investigation.  See also “How to Manage a Multi-National Anti-Corruption Investigation” (Mar. 20, 2013).

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