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Defense
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July 16, 2026

Inside an internal investigation: a board’s first week

A whistle-blower complaint lands on the audit committee’s desk. What the first seven days should look like.

Daniel Reyes
Written by
Daniel Reyes
Partner
Inside an internal investigation: a board’s first week

Article

The first week of an internal investigation sets its credibility with regulators, auditors and employees.

Choose independent counsel

Company counsel who advised on the underlying conduct should not investigate it.

Scope narrowly, then expand

A defined scope protects privilege and keeps the investigation moving.

Report in writing

Oral briefings are forgotten. Written reports are what regulators ask for.

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