Tagged: Internal investigation nightmare scenarios

Lessons Learned from Ericsson’s DPA Breach: An Internal Investigation Nightmare (Part III of III)

Lessons Learned from Ericsson’s DPA Breach: An Internal Investigation Nightmare (Part III of III)

This is not your typical FCPA enforcement action Lessons Learned column.  Instead, Ericsson’s breach of its DPA presents a laundry list of internal investigation errors – as a practitioner in this area, this is the nightmare scenario.  It is a cautionary tale for all investigators, whether conducted by internal staff or outside counsel. Before getting into the nitty-gritty of the internal investigation deficiencies, I would...