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From Baksheesh to BriberyUnderstanding the Global Fight Against Corruption and Graft$
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T. Markus Funk and Andrew S. Boutros

Print publication date: 2019

Print ISBN-13: 9780190232399

Published to Oxford Scholarship Online: May 2019

DOI: 10.1093/oso/9780190232399.001.0001

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The Delicate Task: Guide to Investigating Allegations of Company-Internal Misconduct

The Delicate Task: Guide to Investigating Allegations of Company-Internal Misconduct

Chapter:
(p.521) 19 The Delicate Task: Guide to Investigating Allegations of Company-Internal Misconduct
Source:
From Baksheesh to Bribery
Author(s):

Andrew Boutros

Publisher:
Oxford University Press
DOI:10.1093/oso/9780190232399.003.0019

Conducting internal investigations requires a delicate balancing act for lawyers. The most immediate goal of any internal investigation is discovering the truth. But in the complicated real world occupied by today’s companies, the search for the truth finds itself in constant tension with other important, and often outcome-determinative, considerations. Nevertheless, it is critical that companies conduct an appropriately scaled, appropriately overseen investigation. This chapter first discusses the value of an internal investigation. It then offers a few words on the role of the board of directors when management or a board member is implicated, before describing in detail the basic steps a company should follow in conducting its investigation.

Keywords:   internal investigation, FCPA, UK Bribery Act, foreign official, bribery, corruption, anti-corruption, graft, whistle-blower

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