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Denver Office:
6400 S. Fiddlers Green
Circle
Suite 1820
Denver, CO 80111
Tel: 720.200.0676
Fax: 720.200.0679
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Washington DC Office:
The Army and Navy Club Building 1627 I Street,
NW
Suite 850
Washington, DC 20006
Tel: 202.293.6840
Fax: 202.293.6842
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A company that suspects its employees
or officers have engaged in misconduct
— whether violations of the securities
laws, violations of government contract
rules, or other wrongdoing — must
give serious consideration to conducting
an internal investigation. Good counsel
can help you determine the consequences
on any public reporting obligations, decide
whether you should (or determine if you
must) self-report the conduct to the government,
and help you investigate the facts and
circumstances in a manner that best preserves
your privileges and options. Experienced
lawyers can help persuade prosecutors
or other government authorities to decline
adverse action, or at least to minimize
any adverse action that is taken. They
can also recommend remedial actions, personnel
changes, or new compliance programs to
prevent similar events from happening
again.
Steese ♦ Evans ♦ Frankel,
P.C. has represented numerous clients
in internal investigations arising in
a variety of areas and in different industries.
Examples of work by Firm attorneys include
the following:
- Internal investigation
on behalf of a large defense contractor
involving allegations of potential
mischarging to a government contract.
The Firm helped the company make a
self-disclosure to the government
in accordance with the FAR Mandatory
Disclosure Rule and navigate the government's
subsequent audit and investigation.
- Internal investigation
of the procurement practices of the
Kabul, Afghanistan office of an international
development organization. The investigation
involved significant witness interviews
and other on-site work in Kabul. The
Firm was able to convince government
agents who had already begun their
own investigation to stand down in
favor of the Firm's investigation
and report.
- Internal investigation
of the recruiting and financial aid
practices of a for-profit college.
The Firm interviewed over 200 individuals
spread across 17 campuses nationwide
and the university's online college,
reviewed and performed forensic analysis
of numerous documents, and produced
an over-300-page report of findings
and recommendations — all in
seven weeks.
- Internal investigation
on behalf of the United States Olympic
Committee in connection with the award
of the 2002 Winter Games to Salt Lake
City. Following presentation of the
results of that investigation to the
Department of Justice, DOJ declined
to take action against the USOC or
any of its employees.
- Internal investigation
on behalf of Qwest Communications
in connection with accounting and
disclosure issues pertaining to a
particular equipment transaction.
The Department of Justice declined
to take action against the company.
- Internal investigation
on behalf of an environmental laboratory
related to potential reporting issues.
The Firm successfully persuaded the
Environmental Crimes Section of the
Department of Justice to decline criminal
charges following a four-year grand
jury investigation. The Firm prepared
a corporate compliance and ethics
manual and training program that the
laboratory implemented.
- Internal investigation
on behalf of a large defense contractor
involving allegations of potential
misuse of another company's proprietary
information in the competition for
a government contract.
- Internal investigation
on behalf of a large soap product
manufacturer regarding Clean Water
Act issues.
- Internal investigation
on behalf of a large international
financial institution in connection
with the suspected theft of confidential
information.
- Internal investigation
on behalf of a large defense contractor
regarding potential Procurement Integrity
Act violations. The Firm provided
advice on employee retraining and
enhanced compliance measures.
- Internal review
on behalf of a leading global security
company concerning the allowability
of charges related to work in Africa
under a contract with the U.S. Department
of State.
For more information about our internal
investigations practice, contact:
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