Internal Corporate Investigations

We begin by assessing the allegations and risks to determine whether a full investigation is warranted and estimate its scope, timeline and budget. Our objective is to establish the facts, test alternative explanations, trace assets and build the evidentiary foundation for protecting the company’s assets and reputation, including in criminal or civil proceedings.

Defining Scope and Oversight

We identify the client, conduct conflicts checks and agree on the investigation’s scope, access to evidence, specialist support and procedures for expanding the review as new facts emerge. We safeguard the team’s independence and establish reporting lines to authorized decision-makers free of conflicts, such as supervisory board or audit committee members. From the outset and throughout the investigation, we assess mandatory reporting obligations and the merits of voluntary self-disclosure, considering applicable law, privilege and confidentiality obligations, the client’s interests, and risks to pending proceedings. [1]

Preserving Evidence and Managing Immediate Risks

Within our authority, we implement a legal hold immediately, while the scope is being finalized: issuing preservation instructions, suspending automated deletion and arranging lawful, proportionate data collection. We preserve originals and metadata, verify copy integrity and document chain of custody. For individuals whose conduct is under review, we recommend proportionate restrictions on system access, segregation of duties and, where legally justified, temporary suspension from duties to prevent evidence loss or interference with participants. [2]

Establishing the Facts and Tracing Assets

We build a chronology and evidence matrix identifying corroborating evidence, inconsistencies and gaps. Our e-discovery workflow includes collection, deduplication, keyword searches and chronological review of communications and files. Through forensic accounting, we reconcile payments with contracts and accounting records. We examine counterparties, beneficial ownership and transaction approvals to identify who received the funds and which assets may be available to satisfy a judgment.

Conducting Interviews

We prepare interview outlines for individuals whose conduct is under review and other knowledgeable witnesses. We first obtain each person’s own account, then probe inconsistencies. We explain whom we represent and the limits of confidentiality. We conduct interviews in accordance with applicable employment and data protection laws and the individual’s right to counsel. We document responses accurately in interview memoranda and implement anti-retaliation measures for those reporting concerns, including whistleblowers. Where interests conflict, we address the need for independent counsel.

Reporting Findings and Assessing Exposure

We distinguish substantiated facts, disputed accounts, conclusions and unresolved issues. We assess legal exposure, potential criminal and civil liability, and financial loss. We recommend asset protection and recovery strategies consistent with the client’s lawful interests.

Implementing Remediation

Based on root cause analysis, we recommend measures to stop misconduct and strengthen internal controls, with designated owners, deadlines and effectiveness testing. We also support implementation when separately engaged to do so. [3]

We safeguard confidentiality and verify compliance with data access and transfer requirements in every jurisdiction where data is stored or processed. Involving counsel does not automatically make all materials privileged. We agree with the client who may receive our findings. We use AI only after reviewing confidentiality safeguards and verify its outputs against source materials.

1 Evaluation of Corporate Compliance Programs, U.S. DOJ Criminal Division, updated September 23, 2024.

2 SFO External Guidance on Corporate Cooperation and Enforcement in relation to Corporate Criminal Offending, April 24, 2025.

3 ISO/TS 37008:2023. Internal investigations of organizations — Guidance.