Internal investigations

The immediate steps you take when a conduct issue arises can have a significant impact on the outcome of an internal investigation, whatever the size or potential exposure to your business.

Internal investigations may be conducted for a range of different reasons. It may be necessary to undertake urgent enquiries regarding conduct concerns by a business function or an individual, or an investigation may be prompted by matters arising during the course of business-as-usual reviews. You may also wish to proactively review the adequacy of your policies and procedures to identify potential areas of risk.

When should you carry out an internal investigation?

Law enforcement agencies, regulators and other stakeholders expect businesses to demonstrate good corporate governance. In recent years, this expectation has extended beyond addressing financial health, and criminal or regulatory misconduct, to include corporate culture, values and behaviours.

Whether it is suspected employee fraud, insider trading, bribery, accounting irregularities, sexual misconduct or allegations of bullying or harassment, a failure to adequately address concerns in your business can increase your potential exposure to criminal, regulatory or reputational risk.

Our strategic approach to mitigate risk

We are well placed to guide you through your investigation and advise on any necessary remediation steps. Our team have deep experience of conducting internal investigations for both private and public companies, colleges and universities, charities and associations across a wide range of sectors including sport, life sciences, financial services, construction, manufacturing and energy. We have defended corporations and their former and current senior executives against prosecution or enforcement action.

As experienced investigation lawyers, including financial regulators, former prosecutors and criminal barristers, we will work with you to effectively and efficiently manage the risks through targeted investigation and remediation, while navigating through the simultaneous employment, commercial and reputational considerations that may arise.

During an investigation, we can arrange for the collection, retention and review of all data (including digital devices), conduct interviews with witnesses, prepare reports of findings and make recommendations. Where appropriate, our team can also advise on reporting obligations including decisions on whether to self-report and liaise with law enforcement agencies and regulators, including the FCA and the Charity Commission.

Every situation is different. We adopt a tailored, strategic approach to help you effectively manage and mitigate risk.


2022 Legal 500 UK, leading firm for financial services: contentious

2021 Chambers UK, leading firm for employers

2021 Legal 500 Asia Pacific, leading firm for white collar crime


Depth and breadth of experience. Cross working of expertise across forensic teams to gain an advantage. Diverse group of people.

Legal 500

The white-collar crime practice at Withers KhattarWong LLP has extensive experience in conducting corporate investigations and advising on high profile white-collar matters.

Legal 500

Elaine Aarons is distinguished by the depth of her experience advising senior executives. She is noted for her work on terminations and investigations and is valued for her understanding of the financial services sector.

Chambers HNW

Meet the team

Track record

Internal investigation into alleged furlough fraud

Conduct of an internal investigation into whistleblower allegations of widespread abuse of the Coronavirus Job Retention Scheme ("furlough fraud") and advising on engagement with HMRC.

Representing a high-profile sports and leisure plc

Conduct of an internal investigation for a well-known sports and leisure plc following allegations of financial impropriety resulting in underpayments to HMRC and significant interest from the SFO and FCA. Following the conclusion of our investigation, we advised the Board on engagement with the SFO.

Internal investigation for high-profile performing arts institution

Following allegations of employee misconduct and theft made by a whistleblower we were instructed to conduct an internal investigation. At the conclusion, we advised on reporting obligations to the police and Charity Commission and advised the trustees on employment and data protection issues arising from the investigation.

Internal investigation following alleged employee misconduct, bribery and corruption

Acted for a global real estate firm following whistleblower allegations of employee misconduct, bribery and corruption. At the conclusion of the investigation, we supported the company's global anti-corruption team to assist with additional multi-jurisdictional ancillary investigations.

Assisting a national charity to locate stolen funds

Conducted an internal investigation for a national social welfare charity into suspected employee fraud. In tandem, we were able to successful obtain a Norwich Pharmacal order allowing our client to locate the stolen funds.

Biotechnology company

Engaged to conduct an internal investigation for a listed biotechnology company following an investigation by the Health and Safety Executive and National Counter Terrorism Security Office regarding a potential breach of containment level requirements for dangerous pathogens.

Advising directors and the audit chair of a financial services firm

In respect of an employee fraud within an overseas subsidiary, restatement of company accounts and repeated failure to comply with the Companies Act. Advised on engagement with auditors, regulators and in respect of a complaint to the ICAEW. Successfully representing a number of directors facing prosecution for offences under the Companies Act.

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