FCPA Compliance Report

10 Core Principles for Effective Internal Investigations with Michelle Peirce


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Welcome to the award-winning FCPA Compliance Report, the longest-running podcast in compliance. In this episode, Tom Fox welcomes Michelle Peirce from Hinckley Allen, where she co-chairs the White Collar and Government Enforcement Group.

They take a deep dive into Michelle’s article on the 10 Core Principles Common to Internal Investigations, discussing topics such as the importance of understanding the investigation’s purpose, maintaining privilege, the role of an engagement letter, deciding between written reports and verbal summaries, and the significance of billing and internal communications. Michelle also shares her insights from her professional background, including her experience as a special assistant district attorney, and touches on current pressures on compliance tied to self-disclosure to the DOJ. The conversation offers a comprehensive guide for organizations on conducting successful internal investigations.

Key highlights:

  • Role and Challenges in Internal Investigations
  • Core Principles of Internal Investigations
  • Importance of Privilege and Engagement Letters
  • Written vs. Verbal Reports
  • Order and Structure of Investigations
  • Professionalism and Billing in Investigations
  • Resources:

    Michelle Peirce on LinkedIn

    Michelle Peirce at Hinckley Allen

    10 Core Principles Common to Internal Investigations

    Tom Fox

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    FCPA Compliance ReportBy Thomas Fox

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