Common law and civil law legal systems approach the protection of confidential attorney-client communications from fundamentally different angles. Often, the issue of whether a communication is confidential depends on the role of the attorney, with in-house counsel sometimes falling outside the scope of privilege protections, a distinction that becomes complicated in the context of internal investigations. This guest article by Paul Hastings attorneys Tara Giunta and Morgan Heavener explores the state of privilege in various jurisdictions and its implications for companies investigating potential corruption issues. See “Crafting and Delivering Effective Upjohn Warnings” (Apr. 18, 2018).