I recently co-authored an article with my colleagues John Kelly, Bryan King and Robert Platt discussing the vital steps that government contractors should take when conducting an internal investigation. As outlined in the article,  the following measures are key components of any internal investigation:

  1. Assembling an appropriate investigation team
  2. Preserving privilege
  3. Preparing an investigation work plan
  4. Information gathering
  5. Litigation holds
  6. Witness interviews
  7. Investigation report
  8. Implementing corrective actions and considering disclosure

As stated in the article, “While an effective internal investigation cannot always eliminate negative consequences, it can identify liabilities, assess witnesses, develop helpful facts, spot weaknesses in a contractor’s compliance program and limit future compliance violations.”

The full article, “Contractors in the Crosshairs: Investigations Passing Government Scrutiny,” was published June 22 by Westlaw Journal – Government Contract and is available in the PDF.
Download Document – Westlaw Journal Government Contract (June 22, 2015)