Providing sound representation on behalf of companies, boards of directors, audit committees, and private individuals facing allegations of business misconduct, corporate misgovernance, and compliance infractions is a hallmark of Vinson & Elkins’ Internal Investigations practice. Clients across the globe in a variety of industries call on our Internal Investigations lawyers, often urgently, for informed advice on issues related to bribery and corruption, securities fraud, breach of fiduciary duties, employment, accounting improprieties, business ethics, and criminal and regulatory matters. Recognizing that alleged misconduct can lead to heightened public scrutiny from government regulators, our lawyers act efficiently to develop the facts and analyze claims, apply evolving laws to specific business needs, dispel or manage potential corporate crises, and provide proactive counsel to help avoid future claims.
Our established Internal Investigations practice possesses a thorough understanding of the evolving legal standards under the Foreign Corrupt Practices Act, the UK Bribery Act and other anti-bribery legislation, Dodd-Frank, Sarbanes-Oxley, the False Claims Act, and various other state, federal, and foreign regulations. We put our experience into practice by designing a tailored investigation scope that includes efficient document collection and review, witness interviews, preparation of interim and final oral and written investigative reports, managing press inquiries, and, where appropriate, advising clients on disclosures to the DOJ, SEC, and the UK’s Serious Fraud Office. Sometimes, our representation takes the form of high-profile investigations on a global scale, while other inquiries require a swift, focused review to remain outside the public eye. For every investigation, our team discreetly handles each sensitive step of the process for our clients, while minimizing the disruption of daily business operations.
Internal investigations are often unexpected and demanding. As a result, our clients call on us to provide timely, strategic, experienced, and coordinated representation in virtually every substantive area of law. We also maintain strong working relationships with outside auditors and forensic accountants, enabling us to design and execute an investigation scope that fits our clients’ specific needs.
Representing the Audit Committee of a public technology company in connection with allegations from multiple whistleblowers of Foreign Corrupt Practices Act (FCPA) violations in several countries, including in connection with related SEC and DOJ investigations
Conducted multiple internal investigations for a U.S.-based natural gas products and services company regarding potential FCPA and embezzlement violations, including in connection with the company’s operations in Kazakhstan and Libya
Represented two U.S. companies in a coordinated DOJ and SEC FCPA investigation of the energy industry in West Africa and succeeded in having cases closed without the government taking any action against the clients
(D.C. Cir.); (D.D.C.) — Represented a government contractor in qui tam action in which V&E successfully obtained two writs of mandamus vindicating the contractor’s claim of attorney-client privilege over materials created during an internal investigation led by company lawyers; subsequently won summary judgment on all counts
Conducted internal investigation of FCPA compliance for a public multinational technology company regarding sales practices in the Middle East
Represented an energy company in an internal investigation into allegations of impropriety in the company’s procurement group, including conflicts of interest with major vendors and an allegation of misappropriation of company assets
Conducted an internal investigation, in cooperation with the SEC, for a public company into allegations of potential violations of the Foreign Corrupt Practices Act in China and Hong Kong, and allegations of undisclosed director conflicts of interest
Represented the board of directors of a large, privately held real estate development and construction company in an internal investigation into whether one of its branch offices was engaged in an office-wide scheme to defraud the company and its customers on a number of private and government-funded construction projects
Conducted an internal investigation for a private construction company into allegations of employee fraud and overbilling government agencies
Represented Audit Committee of a public telecommunications company in an internal investigation of pay-for-play leading to the award of a contract from a local government
Conducted an expedited internal investigation for a private international company into potential violations of the Foreign Corrupt Practices Act and federal anti-money laundering laws associated with suspicious payments in Africa
At Vinson & Elkins, we bring decades of knowledge, skill, and experience to our clients’ most complex legal matters.
Discover our latest:
Event Recaps
FCPA and White Collar Enforcement Under the Trump Administration
V&E lawyers discussed FCPA and anticorruption enforcement and how DOJ’s new memos demonstrate the Administration’s shifting white collar enforcement priorities.
June 5, 2025
June 5, 2025 • 2-minute read
Client Alerts
On February 27, 2025, the Financial Crimes Enforcement Network (“FinCEN”) announced a suspension of enforcement actions related to the Corporate Transparency Act (“CTA”).
March 6, 2025 • V&E CTA Update
March 6, 2025 • 2-minute read
Client Alerts
Corporate Transparency Act: Once Again Enforceable – New Compliance Dates Apply
As we previously discussed, on January 7, 2025, the U.S. District Court for the Eastern District of Texas issued a nationwide injunction delaying the implementation of the Corporate Transparency Act’s (“CTA”) reporting requirements (Smith, et al. v. U.S. Department of the Treasury).
February 21, 2025 • V&E CTA Update
February 21, 2025 • 2-minute read
Client Alerts
On January 23, 2025, the Supreme Court granted the government’s motion to stay a nationwide injunction that was issued by a Texas federal judge in the case Texas Top Cop Shop, Inc. v. McHenry.
January 28, 2025 • V&E CTA Update
January 28, 2025 • 2-minute read
Client Alerts
As we previously discussed, on December 5, 2024, the Department of Justice (“DOJ”), representing the Department of the Treasury, submitted a notice of appeal to the U.S. Court of Appeals for the Fifth Circuit, challenging a memorandum opinion and order issued by Judge Mazzant of the U.S. District Court for the Eastern District of Texas.
December 30, 2024 • V&E CTA Update
December 30, 2024 • 2-minute read
Client Alerts
As we previously discussed, on December 3, 2024, Judge Amos Mazzant of the U.S. District Court for the Eastern District of Texas issued a memorandum opinion and order granting a nationwide preliminary injunction against the Corporate Transparency Act (“CTA”), blocking implementation of the CTA in its entirety.
December 10, 2024 • V&E CTA Update
December 10, 2024 • 2-minute read
Event Recaps
This program provided an update on emerging threats, security tools to mitigate those threats, and walk step-by-step through a recent ransomware attack.
December 5, 2024
December 5, 2024 • 1-minute read
