Properly Scoped Investigation by Qualified Personnel – How has the company ensured that the investigations have been properly scoped, and were independent, objective, appropriately conducted, and properly documented? These questions were clearly presaged by the DOJ’s Yates Memo and the Foreign Corrupt Practices Act (FCPA) Pilot Program. The pressure on every Chief Compliance Officer (CCO), and indeed company, to get an investigation done quickly, efficiently and most importantly done right is even greater now.