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Internal Investigation Report

An internal investigation report built on an evidence board, where each finding carries its documents, interviews and testing, and a sentence with no exhibit stays out of the board-ready draft.

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The problem

Findings drafted in Word, proved in a spreadsheet, checked the week before

The team keeps its evidence map in a spreadsheet, drafts each finding in Word, and argues over which findings are strong enough to call substantiated. The cite check comes the week before the meeting, when associates open footnote after footnote against the review database and find the ones pointing to the wrong page.

The mistakes that hurt are predictable. A conclusion about what an executive knew rests on one witness's guess. Evidence against a finding never makes it into the draft. A written copy goes to the auditor and puts privilege at risk. Any one of them can cost cooperation credit, open a second investigation, or hand a derivative plaintiff the report.

Built forInvestigations partnersAssociatesSpecial committee chairsForensic accountants

The Problem Today

Every investigation ends in a report to the board, and each unsupported sentence in it is the first thing attacked.

25,000
whistleblower tips to the securities regulator in 2024 published
75%
off the fine range's low end for a near-miss self-disclosure published

Kept in four places today

  • Evidence
  • Memos
  • Drafting
  • Cite checks
  • Footnotes checked lastHundreds of cites opened by hand in the final week
  • Conclusions outrun proofA guess about what someone knew reads as a finding

The Solution

  1. Allegations mappedEvidence for and against each one, across documents, memos and testing
  2. Findings pinned and scoredEach finding carries its exhibits and a strength score
  3. Unproven sentences struckA sentence with no pinned exhibit stays out of the board draft
  4. The partner decidesThe partner moves each finding, then the committee chair adopts the report

Built-in controls

  • Only the partner moves a finding
  • Written copies only to the committee, numbered
  • Matter files never train a model

What You Get

The committee receives findings where each sentence opens its source, and weak claims are caught before the meeting.

10 hours
of associate mapping and cite-checking per report, from 60–100 our estimate
  • Each cite opens its passageQuotes match word for word; memos cited by paragraph
  • Contrary evidence answeredEach finding shows what argues against it
  • Regulator outline, same draftA presentation outline, never the privileged report
On the evidence board

An internal investigation report assembled finding by finding, cite by cite

Nine features in the order the work runs, from weighing each allegation to controlling who holds a written copy.

  1. 01Allegations, for and against

    Each allegation weighed by the passages for it and against it

    How it works

    • Seven allegations, each tagged with where it came from: the hotline report or the auditor's letter
    • A two-sided bar sets passages for against passages against, such as 11 for and 3 against on concealment
    • Selecting one lists its strongest passages on each side, each with its cite
    • Each row names the finding that answers it and where that finding stands

    Investigations partnerSees which allegations the evidence carries and which it answers, before anyone argues about a finding.

  2. 02Evidence board

    An evidence board showing each finding's pins and strength score

    How it works

    • Three columns: substantiated, not substantiated and needs more
    • Each card shows its allegations, its pinned documents, memos and testing, and a five-step strength meter
    • Sentences drafted and cites counted on each card, such as 58 cites under the side-letter finding
    • A gate counts what may enter the draft: 4 findings, 135 sentences, 204 cites

    Investigations partnerReplaces the spreadsheet evidence map with one board that shows how much proof stands behind each finding.

  3. 03Strength rule

    A strength rule that refuses a finding the proof cannot yet carry

    How it works

    • Substantiated needs a strength of 4 or more and at least one document or data pin
    • Testimony alone cannot substantiate a finding
    • At 3 of 5, the concealment finding stays under needs more
    • The refusal names the interview passage the evidence finder has proposed

    Investigations partnerKeeps a finding about what an executive did away from the committee until the evidence is strong enough to stand behind it.

  4. 04Proposed pins

    Proposed pins that wait for an associate to accept or reject them

    How it works

    • Asked for support, the evidence finder searches 180,000 documents, 41 memos and 212 tested deals
    • It ranks 2 pins out of 23 candidate passages, each with why it matters
    • It also reports what it could not find: nothing for the CFO sentence
    • Nothing is pinned until an associate accepts it

    Senior associateGets the second independent source a finding needs out of the review set, and keeps the choice of what to pin.

  5. 05Paragraph drafted

    A cited paragraph that drafts itself when the partner decides

    How it works

    • Moving a finding drafts its paragraph, one fact per sentence
    • Each sentence carries the exhibit, memo paragraph or test it rests on
    • A sentence with no pinned exhibit is struck through and held out, with the reason
    • The draft gate moves to 141 sentences, 210 cites and 1 held out

    Investigations partnerCan say each sentence of the finding to the committee knowing its source, and sees the one claim about the CFO that has none.

  6. 06Interview memos

    Interview memos read for what a witness knew versus assumed

    How it works

    • The memo list shows 41 of 41 warnings recorded and the passages pinned from each memo
    • A passage that only assumes knowledge is tagged and left unpinned
    • A contradiction check compares the memos with each other and with the pinned documents
    • It found 1 contradiction on a drafted sentence among 312 factual statements

    Senior associateCatches the line where a witness says he assumed someone knew, before it is drafted as a fact about that person.

  7. 07Board report

    A cite check that must pass before the partner can approve

    How it works

    • The draft reads in report order, each factual sentence with its cite chips
    • The cite checker opens each cite and matches quotes word for word
    • Approval waits until the current version passes the cite check
    • Here, 210 of 210 resolve and the partner approves draft v7

    Investigations partnerMoves the cite check off the associates' last weekend and makes it a gate on the partner's approval.

  8. 08Remediation

    Remediation steps, each tied to a finding, an owner and a date

    How it works

    • Six recommendations, from routing customer letters through the deal desk to commission clawback reviews
    • Each names its finding, its owner and its due date
    • The personnel recommendation is written by the partner, never by an agent
    • All six go to the committee chair to adopt

    Special committee chairGets a short list of what to fix, who owns it and by when, each step traceable to the finding behind it.

  9. 09Privilege and distribution

    Numbered, watermarked copies that go to the committee and nobody else

    How it works

    • The privilege guard puts the legend on each of the 64 pages
    • Three read-only copies, each watermarked with its reader's name, with no download
    • The auditor and the full board are briefed orally, with no written copy
    • Each open is logged with name, time and copy number

    Investigations partnerProtects privilege over the report and the memos behind it by controlling who holds a written copy.

Five findings, 141 sentences and 210 cites in the board-ready draft

The internal investigation findings behind the screens: a special committee probe of fourth-quarter revenue at a listed software company, $21.0 million at issue.

FindingDecisionStrengthSentences and cites
Side letters on nine fourth-quarter deals changed payment and return terms, $14.2MSubstantiated5 of 538 sentences, 58 cites
Three order forms dated in the quarter were signed and delivered after it, $6.8MSubstantiated4 of 533 sentences, 49 cites
The sales vice president kept the side letters from finance and the auditorSubstantiated, after one more pin lifted it from 3 to 44 of 56 sentences, 6 cites, 1 struck
Reseller orders and the reserve release were within policyNot substantiated4 of 529 sentences, 47 cites
The reporter's move to a new team was not retaliationNot substantiated3 of 535 sentences, 50 cites
More of the matter

The rest of the special committee report, from one cite to the audit trail

The screens the associate, the partner and practice support open around the board.

One cite, opened at its passageAny cite chip opens the passage it rests on, under the privilege legend, with the finding it is pinned to and a mark that the cite resolves.
A pin rejected, with the reason on recordAn email seemed to show the CFO knew, but its first name is also the deal desk manager's. The associate rejects the pin with that reason.
The associate pins, and the partner decidesWhen the associate tries to move a finding, the board explains the separation of duties and offers to send the decision to the partner.
The struck sentence, kept in view for counselUnder finding 4 the CFO sentence sits struck through with its reason. Counsel sees it; the committee's copy does not.
Who may do what on this matterAgents propose and draft, the associate pins and edits, the partner moves and approves, the chair adopts, and forensic accountants upload testing without opening memos.
Who proposed, pinned, scored and decided each findingOne row per finding, agents and people side by side, then every action in order, from the pins to the copies issued.

A guess about the CFO, a shared first name, late signatures and slow payers

Each was found on the board or in the draft before the committee read a line.

A guess about the CFO, struck

The only basis for saying the CFO knew of the side letters was a sales director's remark that he assumed so. A review of 2,140 of the CFO's emails found no reference, so the sentence is held out.

A first name that pointed the wrong way

An email said someone, by first name only, was fine with the comfort letters. The CFO and the deal desk manager share that name, and the memos show it meant the deal desk manager.

Order forms dated in one quarter, signed in the next

Three order forms dated on the quarter's last day were signed by the customers days into the next one, and their license keys went out after quarter end: $6.8M of revenue.

Side-letter customers paid in 171 days

Customers on the nine side-letter deals took 171 days on average to pay, against 46 on the other 203 deals of the quarter. None of the nine letters was in the contract system.

Five calls on this matter that stay with the partner and the chair

Agents propose, cite and flag. People make these decisions, and the audit trail records who made each one.

Calling a finding substantiatedOnly the partner moves a finding between columns, and only once it meets the strength rule.
Accepting a pinThe evidence finder proposes; an associate accepts each pin or rejects it with a written reason.
Writing about a personNo agent states what someone knew or intended without a pinned exhibit that shows it, and none drafts a personnel recommendation.
Approving the draftThe partner approves the report for the committee, and only after the cite check passes on that version.
Releasing and adoptingThe privilege guard numbers and logs copies but releases none without the partner. The committee chair adopts the report and the remediation.

Findings, privilege and copies in an internal investigation report

What is an internal investigation report?

An internal investigation report sets out what counsel found for a board or a special committee: the allegations, the scope and method, each finding and the remediation. Here it is built on an evidence board, each finding with its pinned evidence and each factual sentence with its cite.

What should an internal investigation report include?

A summary, the scope and method, background, each finding with the evidence for and against it, and remediation steps with owners. The draft here follows that order, adds an evidence map, and answers contrary evidence inside each finding's paragraph.

Should the report to the committee be written or oral?

That is counsel's call, and the solution records it. The committee gets numbered read-only copies, the full board and the auditor are briefed orally, and a government presentation outline is prepared only if the committee elects to self-report.

How does it decide that a finding is substantiated?

It does not. The strength scorer rates each finding on independent sources, documents and data over testimony, and contrary evidence answered. The partner moves the finding, and the board refuses a move to substantiated below the matter's threshold or without a document or data pin.

What happens to a sentence the evidence cannot support?

It is struck through and held out of the board-ready draft with its reason, and counsel can still read it. Nothing is deleted.

Can the forensic accountants see the interview memos?

No. They upload transaction-testing results under counsel's direction and cannot open the memos, which stay privileged work product.

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No sentence reaches the committee
without its exhibit.

We'll rebuild the board, the struck sentences and the cite check from an investigation your team has already reported.

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