Compliance, Investigations & White Collar
No organization can afford to close its eyes to allegations of misconduct without learning about the underlying facts so that appropriate remedial action may be taken. Handled successfully, internal investigations can be highly effective in limiting a company’s exposure to lawsuits, deterring regulatory intervention or the filing of formal charges, and mitigating potential penalties.
Our attorneys have the experience necessary to ensure the effective and ethical handling of internal investigations so that essential facts underlying misconduct allegations are uncovered in a timely fashion. Our attorneys have conducted many investigations and directed interviews of witnesses, ranging from low-level employees to senior executives. We understand the importance of carefully planning the investigation in light of the potential issues precipitating the inquiry, while maintaining sufficient flexibility to adjust the investigative plan where appropriate, such as when new information is discovered that suggests the need to expand, contract or refocus our efforts.
The internal investigation must embrace all relevant fact sources, including witness testimony, internal company memos and emails and any other relevant documentation. For example, in the health care context, we work with compliance professionals having extensive experience in the review of medical claims and billing documentation. After the investigation is completed, our findings are presented to senior management and/or to the Board of Directors, or a special committee of the Board overseeing the internal investigation. Our report will include a comprehensive recitation of facts relating to the matters under investigation, a thorough analysis of applicable laws and regulations in light of those facts, and identification of any compliance or operational deficiencies uncovered. We will then work with our clients to implement any required remedial measures and offer our advice and counsel regarding any potential disclosures to government regulators.