Internal Investigation

It usually starts with an allegation, a hotline report, an audit finding or a regulator's question. The organisation sets a scope, picks independent investigators, preserves documents and follows a written investigation protocol covering confidentiality, interviews, evidence handling and reporting lines. Many teams work from a hypothesis: a working explanation of what may have happened, tested against the evidence and revised as facts emerge, which keeps the work focused. Findings go to a committee or the board, which decides on discipline, repair of controls and whether to self-report to authorities. Counsel is often involved to protect privilege. The term covers any subject, from bribery to harassment, whereas AML investigations and whistleblower cases follow their own specialist routes. Regulators and prosecutors may later ask how the inquiry was scoped and who directed it, and a sloppy file shows gaps that no summary can hide.

A hotline report alleges that a regional sales head pays bribes through a consultant. The audit committee appoints outside counsel, who freezes relevant emails, tests the theory by tracing the consultant's invoices, interviews six people and reports that the invoices lack deliverables. The board dismisses the sales head and informs the authorities.