Venable attorneys have extensive experience in conducting internal investigations, both domestically and abroad, for public and private corporations as well as for audit committees and other special committees. Our attorneys have conducted investigations in numerous areas, including investigations arising from allegations of accounting fraud, healthcare fraud, government contracting fraud, insider trading, executive improprieties, violations of the Foreign Corrupt Practices Act, and violations of the federal environmental laws.
We know the importance of conducting investigations that are focused and thorough, yet discrete, and that enable management to readily understand what, if anything, has happened and how to respond. We also regularly assist management in its decisions related to the investigations, such as those regarding:
- Whether the company should discipline or terminate employees involved;
- How to deal with employees who may be whistleblowers, or otherwise cooperating, with a governmental entity;
- What remedial measures are warranted and how to implement them;
- Whether to self-report any conduct discovered; and
- Whether to waive attorney-client privilege.
Our group consists of professionals with prior experience and senior positions in numerous branches of both federal and state government, including the Department of Justice, various U.S. Attorneys offices, various state Attorneys General offices, the U.S. Securities and Exchange Commission, the Office of the Comptroller of the Currency and the Federal Deposit Insurance Corporation. Our professionals are resident across all of our offices nationwide. We work closely with lawyers in the firm's other practice areas to ensure that our clients benefit from the breadth and depth of the firm's substantive expertise.
- Conducted internal investigation into business activity of companies providing oil logistics support services to energy companies in Port Harcourt, Nigeria, to respond to U.S. Senate Permanent Subcommittee on Investigations inquiry and parallel DOJ investigation.
- Conducted an internal investigation and represented a defense contractor before the SEC and Department of Justice regarding allegations of bribing officials of a South American government.
- Conducted internal investigation on behalf of audit committee of publicly traded homebuilder in connection with an SEC financial fraud investigation. After we presented our findings to the SEC staff, they closed their investigation, declining to recommend that any enforcement proceedings be brought against the homebuilder or any individual employees.
- Conducted an internal investigation for a multi-national software company regarding suspicious transactions by one of its Asian sales representatives.
- Conducted an investigation on behalf of the audit committee of a large, public multi-national industrial corporation into allegations of accounting improprieties. During the process we worked extensively with the company’s outside auditors to facilitate the restatement process and presented the results of the investigation to the SEC, which itself had commenced an investigation, and which largely adopted our findings of no wrongdoing.
- Conducted an investigation on behalf of Fortune 500 company involving alleged Medicaid fraud in prescription drug sales.
- Conducted an investigation on behalf of the special litigation committee of the board of directors of a large public oil company involving alleged violations of the Foreign Corrupt Practices Act and the federal securities laws caused by senior officers' use of corporate funds to make payments to foreign officials in exchange for supplies of crude oil.
- Conducted investigation on behalf of a special committee of the board of directors of a large public financial institution involving allegations of money laundering regarding affiliated Russian banks.
- Conducted an investigation on behalf of Fortune 100 public paper products company involving allegations of violations of the Clean Air Act.
- Currently representing a senior executive of a large multi-national corporation in an internal investigation and in a Department of Justice criminal investigation surrounding allegedly unlawful payments in West Africa and the former Soviet Union.
- Currently conducting an investigation for a U.S.-based government contractor involving potential FCPA problems in Iraq and Afghanistan, which includes conducting investigations in both countries.
Conducted an internal investigation into Asian buying agents of large U.S. retailer for FCPA concerns.
- Conducted an internal FCPA investigation for a multi-national software company regarding suspicious transactions by one of its sales representatives in China.