Defense
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.

Written by
Daniel Reyes
Partner

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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