CCM Compliance Investigations & Internal Reporting

Question 1

When initiating an internal compliance investigation, which action is most critical to take first to preserve attorney-client privilege?

Accepted Answer

Retain outside legal counsel to direct the investigation

Answer

Notify all employees of the pending investigation via company-wide email

Answer

Transfer all relevant documents to the HR department

Answer

Begin interviewing the subject of the investigation immediately

Question 2

An employee reports a potential FCPA violation through the anonymous hotline. The compliance manager's FIRST step should be to:

Accepted Answer

Conduct a preliminary assessment to determine whether a full investigation is warranted

Answer

Immediately terminate the employee identified in the report

Answer

Self-report the potential violation to the DOJ before any internal review

Answer

Archive the complaint and monitor for additional reports before acting

Question 3

Which of the following best describes the 'Upjohn warning' in the context of a compliance investigation?

Accepted Answer

A Miranda-style notice informing employees that company counsel represents the company, not the individual employee

Answer

A regulatory requirement to disclose investigation findings to the SEC within 30 days

Answer

A whistleblower protection notice given to employees before they file a complaint

Answer

A data retention hold placed on electronic communications during an investigation

Question 4

During an internal investigation, a compliance manager discovers that a key witness has deleted relevant emails. The most appropriate immediate response is to:

Accepted Answer

Issue a litigation hold notice and involve IT to attempt forensic recovery

Answer

Close the investigation since evidence has been destroyed

Answer

Report the witness to law enforcement for obstruction of justice

Answer

Disclose the deletion to the board of directors before taking any other action

Question 5

A compliance investigation concludes that a mid-level manager engaged in expense fraud totaling $8,000. Which factor most strongly determines whether to self-disclose to regulators?

Accepted Answer

Whether the conduct was isolated or indicative of a systemic control failure

Answer

The dollar amount of the fraud relative to company revenue

Answer

The number of years the manager has been employed at the company

Answer

Whether the manager has previously received compliance training

Question 6

Which of the following is the primary purpose of documenting the chain of custody for evidence collected during an internal investigation?

Accepted Answer

To demonstrate the evidence was not tampered with and is admissible if the matter becomes litigation

Answer

To satisfy annual audit requirements for document retention

Answer

To allow employees to review what evidence was collected about them

Answer

To provide a summary of the investigation for the compliance training program