31 Days to a More Effective Compliance Program

Issues in Cross Border Investigations

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In an article, entitled “Internal Investigations, How to Conduct an Anti-Corruption Investigation: Developing and Implementing the Investigation Plan”, Mara Senn, now Director & Senior Counsel, Global Compliance Investigations at Zimmer Biomet and Michelle K. Albert, former lawyer at Arnold & Porter discussed cross-border investigations. They considered the following issues.

Offer interview translations.

Avoid cultural pitfalls.      

Observe data privacy restrictions.

Comply with labor requirements.

Be aware of other local requirements.

Put forms in native translations.

Preserve the attorney-client privilege.

Prepare for local enforcement actions.

Prepare for security risks.

Protect whistleblowers.

Three key takeaways:

  1. Use translators and translations of key documents in witness interviews.
  2. Use local counsel to facilitate the investigation and to help navigate any local anti-corruption investigation issues.
  3. Never, never, never retaliate. The SEC will pay whistleblower bounties for non-U.S. citizens.


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    31 Days to a More Effective Compliance ProgramBy Thomas Fox
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