Internal Investigations Blog

Titillating bits of testimony that came out in the wake of the Africa Gun Sting trial show why old truisms are just that: old and true.  In this instance, the adage that works so well is the one about those who lay down with dogs getting fleas.  All investigators – both internal and external – need to be wary of growing too close to their witnesses in any inquiry, regardless of type.

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.

Recently, The Associated Press reported that the Department of Justice continues to increase its investigations of local police departments for civil rights and related violations.  This holds to a trend that began in 2008 and has serious implications for municipalities that ought to take a cue from the private-sector in responding to complaints of wrongdoing.  Citizen complainants and employee complainants are both essentially whistleblowers and the response of local government ought to be the same as that of private enterprise.

Two excellent articles this summer have discussed resource allocation at the Department of Justice and its impact on government enforcement actions.  Long story short: with limited resources and stepped up activity in two hot areas – the Foreign Corrupt Practices Act and False Claims Act – bad numbers are up and good numbers are down.  While many companies see the underlying reasons as problematic, they shouldn’t and ought to take full advantage of the time afforded them to continue to conduct top-notch internal investigations that will ultimately work in their favor.