Outside Counsel Perspectives on Key Steps in Internal Investigations

Once a company receives an allegation of a possible FCPA violation, it must make decisions on a wide range of questions, including whether an investigation is even needed and whether the company should disclose to enforcement agencies. In a recent Strafford webinar, John Davis, a member at Miller & Chevalier, and Kimberly Parker, a partner at WilmerHale, shared their insight on the key issues that companies need to consider throughout the process. If “employees do not think that the company takes allegations of misconduct seriously, they will not report,” Davis said. “They will not have faith in the other key aspects of the compliance program, such that you will inevitably have issues down the road.” See “Investigation Strategies During Social Distancing” (Apr. 1, 2020).

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