Planning for global investigations and crisis response

Incidents of fraud or misconduct can mark some of the darkest chapters in the life of a company. The resulting financial and reputational damage, distraction from corporate objectives, and demands on executive time and attention are often significant. For global organizations, the complexity and geographic reach of the response to fraud can be overwhelming. The damage caused by a significant fraudulent event often takes years to repair and in extreme cases can prove fatal for an organization.

For most companies, dedicating time and resources to planning for the worst is a worthwhile investment and provides reassurance that, although all such incidents exact a cost, the company has done what it can to plan and coordinate a global response to minimize the immediate and long-term impacts.

Developing a fraud response plan for your organization

Upon discovering fraud, an organization is immediately thrust into a state of heightened stress and urgency. An effective fraud response plan helps streamline your decision making and organize actions in a way that is logical and strategic.

A clear chain of command provides structure for fraud response, while defined (and agreed-upon) action steps for senior executives and corporate directors establish the plan framework. The fraud response strategy should clearly state what information will be communicated to whom and under what circumstances.

Handling global investigations

For incidents with global reach, the complexity of the plan activities increases, introducing additional considerations into an already dynamic decision-making process.

• Building the right team: Success depends on assembling a team with the right mix of skills and experience—typically in forensic accounting, cybersecurity, data analytics and local law. Language proficiency and cultural awareness may be equally important, as is the ability to operate both remotely and in-country.
• Reporting: As the situation develops and information is gathered and assessed, stakeholders, often spread across jurisdictions and time zones, will require timely updates. Regulatory obligations, law enforcement involvement and data privacy laws will also drive reporting timelines and audience. An organized approach to consolidation, assessment and reporting of progress and findings is essential.
• Information collection and data management: The location and format of relevant data and whether it is held centrally or dispersed will shape the investigation’s initial preservation and collection activity. These factors should be assessed and mapped in advance, at least in part—although, depending on the specifics of a fraud incident, forensic technology specialists may be needed to extract data from additional devices or servers. E-discovery platforms like Relativity offer multilingual and remote-access capabilities to streamline the review process.
• Legal and regulatory obligations: Each jurisdiction will present its own legal landscape and unique challenges. Investigators may need to navigate “blocking statutes” that restrict cross-border information sharing, data privacy laws like the European Union’s General Data Protection Regulation, and whistleblower protection regulations. Understanding local rules on legal privilege and confidentiality is vital to protect your organization’s interests.

Staying ahead: Technology strategy and competence

The pace of technological change requires any fraud response plan to constantly adapt to and incorporate the latest thinking and approaches to analytics, automation and presentation. A strategy that maintains tech-literate teams and leverages advanced technology to enhance investigative capabilities will keep your organization ahead of the curve.

Outside professionals can bring years of experience handling similar types of fraud incidents. External firms typically provide investigative professionals, forensic accountants, data analytics specialists, and access to artificial intelligence tools, e-discovery platforms and other forensic technologies that enhance investigative work. These capabilities are expensive to maintain internally and may not be readily available within your company’s own team—but outside consultants can often provide them in a comprehensive and cost-effective manner.

Why it matters

Global investigations of fraud and misconduct are inevitable for organizations operating in multiple countries. For most companies, planning for the worst is a worthwhile investment that can minimize the immediate and long-term impacts of such events.