Conducting Effective Internal Investigations Involving Export Violations

Evaluating Key Issues Including: Whether to Investigate, How to Determine the Appropriate Scope, How to Manage the Privilege Issues, Handling Parallel Investigations, and More

A live 90-minute CLE video webinar with interactive Q&A

Wednesday, October 20, 2021

1:00pm-2:30pm EDT, 10:00am-11:30am PDT

Early Registration Discount Deadline, Friday, September 24, 2021

or call 1-800-926-7926

This CLE course will guide counsel on the key issues to manage when conducting effective internal investigations related to export violations under US laws and regulations. The panel will examine the primary factors to consider when determining whether, when, and how to conduct an investigation. Limiting a scattered investigatory approach, avoiding other similar pitfalls, and identifying the areas where the most efficiencies can be gained when assessing the manner in which to conduct the investigation will be reviewed.


When confronted with potential export violations, having a process in place to identify where to start and how to develop a plan to conduct the review. Addressing the foundational issues of who, what, where, why, when, and how will help structure the review and, at the same time, provide the necessary information required to inform management and the board, and engage with the relevant US Government agencies responsible for export compliance and enforcement.

When undertaking an internal investigation, companies and their counsel would benefit from a thorough analysis of the legal, ethical, and practical issues, including whether to conduct the investigation, how to conduct it in a cost-effective manner, how to manage privilege and privacy issues, and confidentiality concerns, among others.

With increasing regulatory scrutiny, counsel must carefully weigh whether to conduct an internal investigation into suspected or alleged violations and how to conduct the investigation in the most effective manner.

Listen as our authoritative panel of international trade attorneys examines the factors to consider in determining whether and how to conduct an internal investigation for export violations. The panel will review the key elements and discuss the potential pitfalls that may occur along the way, including the perils of parallel investigations. The panel will offer guidance to avoid pitfalls and conduct an effective investigation.



  1. Internal investigations for export violations
    1. Discovery of an alleged violation
    2. Considerations for determining whether to conduct an internal investigation
    3. Selecting who will conduct the investigation
    4. Scope
  2. Potential pitfalls
    1. Parallel investigations
    2. Failure to address privacy and consent issues
    3. Waiver of privilege
  3. Avoiding pitfalls
    1. Preserving attorney-client privilege
    2. Managing interviews to balance privacy and consent concerns
    3. Data protection
  4. Post-investigation strategies
    1. Remedial action
    2. Minimizing the risk of further government investigation


The panel will review these and other key questions:

  • What are the key considerations for counsel conducting internal investigations for export violations?
  • What can counsel do to protect privileges and confidential information during an internal investigation?
  • What steps can companies take to minimize the risk of a government investigation?


Cinelli, Giovanna
Giovanna M. Cinelli

Morgan, Lewis & Bockius

Ms. Cinelli is the leader of the firm’s international trade and national security practice. As a practitioner for...  |  Read More

Additional faculty
to be announced.
Attend on October 20

Early Discount (through 09/24/21)

Cannot Attend October 20?

Early Discount (through 09/24/21)

You may pre-order a recording to listen at your convenience. Recordings are available 48 hours after the webinar. Strafford will process CLE credit for one person on each recording. All formats include course handouts.

To find out which recorded format will provide the best CLE option, select your state:

CLE On-Demand Video