Regulatory Compliance Association Reviews

The Anatomy of an Internal Investigation for Asset Managers™

Practice Edge 02

Preparing for, undertaking and reporting the findings of an internal investigation involve a number of considerations that are crucial to its outcome. The nature of the issues to be examined, the time and resources involved, the locations of relevant documents and interviewees, the disruption to the organization and lastly the associated costs, are all factors to be considered before embarking on an internal investigation. Properly balancing these and other factors to determine how the investigation should be conducted and by whom, will most often lead to a successful internal inquiry.

The success of an internal investigation can be measured in a number of ways. Perpetrators can be identified and brought to justice, weaknesses in controls can be found and rectified, and organizations can improve upon policies and procedures from reviewing the results of an internal inquiry. In the final tally, an internal investigation must be independent, thorough, ethical, and believable. And it must address the concerns of all constituents.

In order to address these emerging issues and risks, the RCA’s Law and Masters Concentration Faculty, and Guest Lecturers shall provide an in depth, candid discussion and provide practical commentary regarding key concerns including:

  • Determining who should conduct the investigation; inside counsel, outside counsel or third-party;
  • Protecting the investigation and the results – privilege and other considerations at the time of commencing the investigation and throughout its completion;
  • Ethical rules for conducting an internal investigation;
  • Investigative techniques and third-parties – locating documents, conducting interviews and relationships to “witnesses”;
  • Reporting the results of an internal investigation – how, to whom; and
  • The special problems of social media and internal inquiries.

Session Chairman:
Walter Zebrowski, JD, CPA, Principal, Hedgemony Partners
Chairman, Regulatory Compliance Association

Senior Fellow From Practice:
David Holley, JD, Senior Managing Director, Kroll

Guest Lecturers:
Andrea Gibson Product Director, Kroll Ontrack

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