Corporate executives and directors are beset by an ever-increasing variety of internal investigations, some based on concerns that come to light within the company and others driven by government inquiries and other external forces. Our attorneys have extensive experience conducting investigations on behalf of corporate boards, audit committees, and special management committees.
We are skilled at navigating the complexities of such investigations both nationally and internationally, from working with IT specialists to gather and sort relevant electronic documents; to identifying and interviewing relevant witnesses in the U.S. and abroad; to navigating the difficult accounting issues that may arise; to clearly and concisely applying relevant legal standards to the information gathered. We also have extensive experience coordinating communications among disparate stakeholders, including board members, company executives, current and former employees, and outside auditors. We pursue our investigations quickly and efficiently in the belief that a thorough and credible internal investigation can have a strong positive influence on the government’s approach toward a corporate client.
- Analyzed a high-tech manufacturer’s historical compliance with U.S. export compliance obligations and its dealings with customers in countries subject to U.S. sanctions.
- Investigated, on behalf of a U.S. public company’s board of directors, allegations of financial improprieties and professional indiscretions by managers of the company’s international offices.
- Conducted an internal factual investigation for a major undersea cable company involving four foreign jurisdictions, issues of foreign government ownership, and disputed international jurisdiction.
- Investigated and analyzed a public company’s revenue recognition policies in the United States, Asia, and Europe, focusing in particular on subsidiaries’ alleged involvement in channel stuffing.
- Analyzed an industrial oven manufacturer’s historical compliance with U.S. export compliance obligations and prepared a rigorous export management policy to ensure compliance going forward.
- Investigated telecommunications companies’ historical compliance with universal service subsidy programs and prepared procedures to ensure compliance going forward.
- Investigated conduct of foreign corporate executives as part of FCPA representations.
- Investigated conduct and accounting at major U.S. financial institution, driven by inquiries from the DOJ related to alleged improprieties in financial markets.