Our Africa Anti-Corruption Practice has previously outlined key considerations for handling internal investigations and remediation of compliance issues in Africa. Here, we take a closer look at a particular aspect of remediation, the root cause analysis. After the dust settles on an investigation identifying misconduct, a root cause analysis can serve as the most effective
Noam Kutler specializes in representing companies and individuals in complex cross-border investigations involving the U.S. Department of Justice, the Securities and Exchange Commission, Inspectors General, and other federal and state regulators.
He has helped guide numerous clients to successful resolutions of inquiries involving allegations of fraud, financial irregularities, violations of the Foreign Corrupt Practices Act (FCPA), and the False Claims Act (FCA). He often leads investigative efforts in parallel with advising companies on comprehensive compliance reviews and remedial actions.
Noam has represented companies and individuals in both federal and state court. In these matters, he regularly has lead responsibility over a variety of substantive areas including:
- questions of privilege;
- enforcement of subpoenas;
- document preservation; and
- the application of various criminal statutes.
He has also advised companies in the lead up to and in the midst of compliance monitorships, and is regularly called upon to help negotiate sensitive issues on behalf of his clients.