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Conducting cross-border internal investigations

Segev Shani ( is Chief Compliance & Regulatory Officer at Neopharm Ltd., Petach Tikva, and Senior Lecturer at the Department of Health Systems Management & School of Pharmacy at Ben-Gurion University in Beer Sheva, Israel.

Monitoring and enforcement are crucial parts of implementing and maintaining a successful compliance program. Organizations should be able to conduct and provide evidence that they perform effective internal investigations, which are usually triggered by an internal complaint, a report, an authority inquiry, or at the request of a competent authority.

Internal investigations present a number of challenges, which become much more complex in the event of cross-border investigations. Different enforcement agencies operate within their own legal and technical frameworks. Any investigation is a dynamic process, and the scope of each investigation can change significantly as it progresses. Therefore, organizations that operate in more than one country face an array of sometimes-conflicting foreign and domestic legal and regulatory requirements. The purpose of this article is to discuss specific issues relevant to conducting a cross-border investigation.

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