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Internal Investigations

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.


Strategic Application of Evolving Laws

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.


Tailored Investigative Scope

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.

Experience Highlights

  • 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

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