Internal Investigations Blog

CVS Caremark, Corp. and Cardinal Health, Inc. find themselves in the crosshairs of a Drug Enforcement Agency investigation in central Florida that threatens both companies’ ability to do business there.  Pinning down who knew what and when within both organizations may lead to some very unpleasant results and the prospect that nobody knew anything is unlikely and lends little comfort.

As usual, Mike Volkov has solid points in a piece he posted this past Monday over at the Corruption, Crime & Compliance blog.  In it, he proffers five suggestions that smaller organizations should follow in order to make certain that they are doing all that they can in attaining compliance and ethics programs that are worth their salt.  One of them has some obvious implications on the internal inquiry front that nonetheless can’t  be overlooked.

The late President Ronald Reagan had a philosophy about arms reduction treaties with the former Soviet Union:  trust but verify. One would think that with recent history bearing out the wisdom of that practice as regards athletic recruiting and eligibility scandals, university administrators would avoid rushing to judgment and proclaiming the innocence of their programs and coaching staffs before the results of internal and external investigations are known.  

In a January 31, 2012 posting, the FCPA Compliance and Ethics Blog reported on a new FCPA investigation tool being deployed by the U.S. government: Internal Revenue Service gum-shoes.  The use and inclusion of these agents will add an additional layer of review to internal and external investigations.