Think of a U.S.-headquartered multinational when it receives an allegation of serious misconduct at one of its overseas operations. Maybe the company whistleblower hotline just got a tip that a secretary in the Buenos Aires office is trading on inside information. Or maybe the U.S. Justice Department has just asked for information about the company’s recent entertainment of a certain government official in Saudi Arabia. Or perhaps an executive at the Toronto office has been complaining to colleagues that the managing director for Canada is harassing her. These are the types of allegations that give rise to an American multinational deciding to initiate a cross-border investigation.

But investigating across borders can be complex, expensive and risky. How does an American-based organization that is accustomed to doing internal investigations domestically within the United States go about investigating some alleged infraction at an overseas facility?