31 Days to More Effective Compliance Programs - Day 19 - The Investigation Protocol

Thomas Fox - Compliance Evangelist
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After the internal report comes in and you have properly triaged the matter, you need to scope out and investigate it promptly, thoroughly, and with competent personnel.

In a presentation, Jay Martin, retired Chief Compliance Officer at Baker Hughes and now Senior Counsel at Willkie Farr & Gallagher LLP, and Jacki Trevino, Senior Director, Advisory Services Group at SAI Global Limited, discussed the specifics of an investigation protocol. It See more +

After the internal report comes in and you have properly triaged the matter, you need to scope out and investigate it promptly, thoroughly, and with competent personnel.

In a presentation, Jay Martin, retired Chief Compliance Officer at Baker Hughes and now Senior Counsel at Willkie Farr & Gallagher LLP, and Jacki Trevino, Senior Director, Advisory Services Group at SAI Global Limited, discussed the specifics of an investigation protocol. It consisted of:

1. opening and categorizing the case,

2. planning the investigation,

3. executing the investigation plan,

4. determining appropriate follow-up, and

5. closing the case.

If you follow this basic protocol, you should work through most investigations, concise and cost-effective. Furthermore, you should have a report at the end of the day which should stand up to later scrutiny if a regulator comes looking. Finally, you will be able to “Document, Document, and Document,” not only the steps you took but why and the outcome obtained.

Three key takeaways:

1. A written protocol created before an investigation is a key starting point.

2. Create specific steps to follow so there will be full transparency and documentation from now on.

3. Consistency in approach is critical. See less -

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DISCLAIMER: Because of the generality of this update, the information provided herein may not be applicable in all situations and should not be acted upon without specific legal advice based on particular situations.

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