If the investigation has determined that wrongdoing has occurred, the company should make the cessation of ongoing violations a priority.  Involved employees should be appropriately disciplined and, if necessary, dismissed.  Investigators should also identify the root causes for the wrongdoing and any potential process or internal controls improvements that could reasonably be implemented by the company.

For investigations with a UK nexus, the company should also determine whether or not it is (or is likely to be) in the possession of any funds or assets obtained as a result of criminal conduct.  It will then need to determine whether or not any notification to the UK National Crime Agency should be made.


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