Common Challenges to Internal Compliance Investigations and How to Deal With Them

Attorneys are often the second line of defense but are the first people called when allegations of internal misconduct arise. This course offers suggestions on how to judiciously leverage limited internal resources and identify allegations that should be investigated by an external third party. With increased scrutiny of corporate compliance programs, now is the time to implement and continuously refine internal investigation approaches to define the organization’s culture of compliance.

Organizations often uncover allegations of internal misconduct, such as violations of the law or the organization’s internal rules, policies, or procedures, from any number of sources within and outside of their four walls. Unfortunately, organizations often lack seasoned investigators and/or a well-documented internal investigation approach to reliably respond to the alleged misconduct. This often results in ineffective and inefficient investigations without meaningful lessons learned to prevent future misconduct. How an organization navigates alleged misconduct can affect its reputation and standing as much as, if not more than, the alleged misconduct itself. Now more than ever before, the increased federal and state law enforcement interest in corporate compliance across a large number of industries warrants organizational leaders to evaluate their internal investigation approach (if any) and use it to help define the organization’s culture of compliance.

Attorneys of all levels are encouraged to attend this course to learn how to plan for internal investigations.

Learning Objectives:

• Explain what an internal investigation is and detail its origination
• Learn when to conduct an internal investigation
• Explore how to appropriately scope an internal investigation
• Detail common challenges that arise before, during, and after an internal investigation