Where Privilege Protection Ends In Internal Investigations

Law360, New York (March 22, 2013, 12:39 PM EDT) -- The heightened anti-corruption enforcement environment of the past several years, particularly of the U.S. Foreign Corrupt Practices Act, has given rise to an escalation in related legal work. Such work ranges from internal investigations into alleged improper payments to “risk assessments” that company counsel conduct to determine weaknesses in, and recommend enhancements to, a company’s anti-corruption compliance program. Additionally, companies may conduct anti-corruption-related internal audits of their operations, whether routine or precipitated by an internal investigation.

The nature of this work implicates a number of privilege-related...
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