Congress enacted the Sarbanes-Oxley Act of 2002 (“Sarbanes-Oxley”) to protect investors by combating corporate crime and improving corporate governance.2 Sarbanes-Oxley requires companies to implement extensive corporate governance policies to prevent and respond to fraudulent activity within the company, including vigilant self-policing to deter and quickly investigate and contain internal financial fraud.

These and other provisions require companies to closely review their policies and procedures regarding internal investigations, and implement the necessary processes and tools to respond quickly and effectively to reports of fraudulent activity.