In an era of the 24-hour news cycle, social media, avaricious plaintiffs’ lawyers and aggressive government enforcement, discrete (and discreet) problems can spin out of control in the blink of an eye. Moreover, Congress has “deputized” the entire corporate work force to serve as law enforcement, providing substantial financial incentives for employees to report wrongdoing by their organizations. Building on the tremendous success of the False Claims Act, Congress established the IRS whistleblower program in 2007 – through which a former UBS employee was recently rewarded $104 million for information about overseas tax shelters – and the SEC whistleblower program in 2010. In this environment, it is more important than ever for companies and institutions to understand how use effectively internal investigations to minimize and possibly eliminate these risks.
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