Integrity Monitoring

When corporations settle civil or criminal charges with government regulators, it is increasingly the case that they are required to appoint or accept the appointment of integrity monitors to ensure compliance with the terms of those agreements, which frequently mandate the implementation of compliance programs, remedial measures and reforms of various kinds.  Integrity monitors are also frequently utilized on major public works projects to ensure probity in the performance of government contracts, either as part of a proactive effort to minimize waste and abuse, or because the contractor or its employees were previously investigated or charged with misconduct.

Kaiser Law Firm PLLC is experienced and well-positioned to assist in this area, either as an integrity monitor or as a shadow advisor to a corporation required to accept such a monitor.  As a federal prosecutor, Mr. Kaiser negotiated an agreement with a major financial institution requiring the appointment of an integrity monitor.  As a senior consulting professional, Mr. Kaiser performed integrity monitorships of individuals and organizations in the healthcare, construction and transportation industries.  Among other things, these assignments required reviewing and drafting compliance program provisions and business codes of conduct, as well as employee training to ensure compliance with ethics and anti-corruption requirements.  In the health care industry, Mr. Kaiser provided monitoring services pursuant to a corporate integrity agreement between a physician and HHS-OIG, which required an annual review of contractual arrangements for compliance with the Anti-Kickback Statute and the Stark Law.  If you are in need of these types of services, Kaiser Law Firm, PLLC is ready to help.

Internal Investigations

Internal investigations can be an indispensable means for businesses to uncover and address potential issues of misconduct within their organizations, whether those issues relate to fraud, discrimination, self-dealing, bribery or other forms of corruption in the workplace.  Sometimes these issues can be revealed through a government subpoena; other times, a company may learn of misconduct through an employee or an anonymous whistleblower.  Whatever the source of the allegations, no company can afford to close its eyes to such matters without learning the underlying facts so that appropriate action can be taken.  Handled successfully, internal investigations can limit a company’s exposure to lawsuits, deter regulatory intervention or the filing of formal charges and mitigate potential penalties. 

Kaiser Law Firm, PLLC has the experience necessary to ensure the effective handling of internal investigations so that the essential facts underlying misconduct allegations are uncovered in a timely fashion.  As a federal prosecutor and senior consulting professional, Mr. Kaiser was responsible for leading numerous corporate investigations and directing interviews of witnesses ranging from low-level employees to senior executives.  Mr. Kaiser also has lectured on the ethical considerations surrounding the performance of internal investigations.  Kaiser Law Firm, PLLC can present its findings to senior management or a special committee of the Board of Directors overseeing the internal investigation, and advise the company in connection with any disclosure of findings to government regulators.