Internal Investigations: What Should You Tell Witnesses About Government Contacts?

You may also like...

2 Responses

  1. Jon May says:

    Michael,

    What do you think of giving such advice prophilacticly. Tell employees on the day they are hired that, dueto the nature of government oversight today, there may come a time they are contacted by government investigators. Should that happen they should report the contact to the gc’s office. And these are your rights.

    This way the advice is not tied to any specific investigation, so it won’t be so alarming if the issue comes up, and it encourages the employees to let the company know about any contacts with government agents. Too remind employees, the rights policy can be periodically emailed to employees along with a reminder that the company believes in ethical and legal practices and this is the hotline number in case the employee learns of something inconsistent with that policy. The killing a lot of birds with a sawed off shot gun approach.

    Jon

  1. August 6, 2012

    […] it’s not always about you and has some remarks on money-laundering compliance. Mike Volkov delves further into internal investigations and reveals the dirty secret of FCPA enforcement. Howard Sklar sounds […]