ABSTRACT

This chapter is intended as a guide for senior managers of organisations and their advisers who need to conduct internal investigations into fraud or incoming, internal, outgoing and competitive corruption.1 Chapter 36 extends the subject to adversarial investigations initiated by a regulatory agency or run collaboratively with one (proxy investigations), possibly after a self-disclosure has been made. Although most of the discussion applies to all regulatory agencies, the Serious Fraud Office (SFO) has been singled out, because for UK companies it is the lead agency.