Friday, March 25, 2005

The Role of Internal Investigations

When a company has issues with government regulators, cooperation can often be crucial is determining what path the investigation will take.  Will it involve indictments, will there be civil penalties, or will nothing happen.  One aspect of this cooperation is often involves the company doing their own internal investigation.  Obviously, an internal investigation can also assist in helping the company make certain that improprieties do not occur in the future and in assessing possible liability for past conduct.  But what happens when the internal investigation turns up more than anticipated.  Often key issues here are going to be - - what to disclose, who the disclosures should be made to, and when should they be made. 

Now take AIG - an internal investigation that turns up new items that may be questionable.  (See Wall Street Journal & New York Times articles) The response to the press is "no comment."  And until the full investigation is complete, one might expect that response to the press.  But then what?

(esp)

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