I watched the webinar from EthicsPoint and Kroll on Investigating Suspected Financial Accounting Irregularities. Jed Davis is the Managing Director in the Business Intelligence and Investigations Division of Kroll and Dave Hess is the Managing Director of the Forensic Accounting and Litigation Consulting Division of Kroll.
Dave emphasized the need to have a plan in place to deal with an investigation.
In Planning the investigation:
- Establish an independent team with required expertise:
- Identify and preserve relevant documents and evidence
- Determine the scope and timing of investigation
- Develop work plan and approach
- Establish internal communication protocol
Some key objectives and considerations are:
- to ensure and maintain rigor and credibility of investigation
- to work with outside counsel to establish and maintain procedures to protect attorney‐client privilege
- communicate with the investigating parties and stakeholders.
- Establish procedures to avoid “scope creep”
- Determine if alleged misconduct was an isolated act or a systemic problem
- Establish verifiable chronology of policies, decision‐making and actions in issue
- Identify internal control deficiencies and make recommendations for improvements
- Report investigation results to stakeholders