At Close Quarters: A CEO’s Guide to Navigating the Unanticipated Government Investigation and Regulatory Enforcement Action: Internal Investigations

News of an unexpected “government investigation”—particularly an investigation of allegations of criminal conduct—can instill fear and trepidation, even panic, among those responsible for the business. Early missteps and hasty over-reactions by unprepared managers can result in enormously negative outcomes when the government later makes decisions about the consequences of misconduct found to have been committed by individual employees or managers.

In his recent work, At Close Quarters, Allan J. Sullivan helps the uninitiated business avoid common mistakes and suggests numerous strategic approaches to recurring investigative scenarios. A seasoned “white-collar” trial lawyer and corporate compliance practitioner, Sullivan advises the business reader not only how best to respond internally at the first sign of trouble, but how to manage the unimaginable—the execution of a search warrant, the receipt of grand jury subpoenas, law enforcement interviews of employees and managers, and the need ultimately to negotiate post-investigation “resolutions” with the government.

Sullivan’s work isn’t just about responses to government trouble, however. Using a series of realistic vignettes, he demonstrates at length the value of the adoption of forward-looking compliance measures and the need appropriately to use internal investigations to ferret out misconduct in the first instance.

Allan J. Sullivan has practiced law for thirty-five years and is experienced in several disciplines-for over ten years he worked as a federal prosecutor in one the United States' busiest judicial districts, for another decade he was as a compliance and investigations partner at one of the world's top international law firms, he served as General Counsel for a major social services agency, and he founded two multi-jurisdictional commercial law firms where he engaged in a white collar defense and investigations practice.

Beyond his substantial experience as a commercial disputes and white collar criminal defense attorney, Sullivan has focused much of his his practice on advising companies regarding their internal corporate compliance challenges, designing compliance and integrity programs and training boards and executive management as to compliance best practices.