It is important to be aware that in cross-border investigations different privilege standards may apply in different jurisdictions, and therefore work product formed during the course of the investigation may receive a different level of protection against future disclosure depending on who created it and where it is created and/or held.  In addition, certain jurisdictions have affirmative requirements to disclose knowledge or suspicion of certain types of criminal conduct; this may also be a factor that investigators will need to consider when approaching an investigation.  For more on this see Attorney-Client Privilege and Secrecy in Transatlantic Investigations: A Comparative Regime Approach (Part I) and Attorney-Client Privilege and Secrecy in Transatlantic Investigations: A Comparative Regime Approach (Part II).