Investigations typically play out over many years. The uncertainty disrupts business operations and obliterates personal sanity. The targets of a government investigation may feel powerless and helpless. As a precautionary measure, leaders should engineer compliance programs to protect against such disruptions. Regular training should help people understand how doing their job correctly will minimize exposure to investigations and charges for white-collar crimes.
Based on our experience, we recommend that business owners use a solid plan to prepare, at the soonest possible time. For example:
- Create documents that clearly show how the organization defines success.
- Create documents that lay out a step-by-step plan, detailing every aspect of the organization. On a regular basis, preferably quarterly, but at least annually, revisit the plan and make adjustments.
- Create tools, tactics, and resources to articulate precisely how the organization functions and allocates resources. Show the investment that the corporation makes to train all staff members, and to communicate the message to all vendors and consumers. Build a system to organize how the corporation keeps records, with effective backup plans.
- Show the steps the corporation takes to measure progress. Make sure that each team member is aware of the documentation, and schedule periodic training to refine best practices.
Leaders should take defensive measures to protect the business and all team members, knowing that investigations begin in secret and can occur at any time.