In this article, Homer Moyer discusses some key factors in controlling costs during an FCPA internal investigation. While investigations can take considerable time and money to complete, there are ways that a company can lower its costs. "Companies are much more attuned to the need to conduct (or have their outside counsel conduct) cost-effective investigations," Moyer said. "The need to investigate continues, but the reported costs of some of those investigations have been breathtaking. Being able to respond to issues by conducting investigations efficiently and in a proportionate, sensible way is on companies' radar screen much more now."

Hiring veteran outside counsel who has previously handled numerous internal investigations can reduce the overall cost of an investigation, if counsel can recognize familiar issues and draw on experience in devising appropriate responses. "There's not a learning curve, and they’re not puzzling over the law. Rather, they’re identifying the issues and developing recommendations about how to respond," Moyer explained.

Another key factor in controlling costs is knowing when to stop an investigation. In some cases, allowing an investigation to go on too long can prolong the process and increase costs unnecessarily. "Sometimes, for example if you uncover a systemic problem, it makes more sense to stop and to promptly address the issue with effective remediation than to continue going to great lengths to uncover more and more examples of the problem," Moyer said.