5/6/19: On his Conflict of Interest Blog, Jeff Kaplan references an article by Notre Dame Law School Professor Veronica Root Martinez, titled Complex Compliance Investigations. In the article, the author focuses directly on compliance investigations. She argues that some recent compliance failures might have been avoided if “… more robust processes … had been in place...
to ensure investigations were conducted in a manner that allowed the firm to analyze information from diverse areas of the firm.” Kaplan’s post links to a second post in the Compliance Program Assessment Blog, which lists a series of questions that should be asked to assess the investigation process itself.