Independent & Internal Investigations

Through decades of experience, Steptoe has earned a national reputation as a go-to firm for boards, audit committees, special committees, companies, and other institutions conducting sensitive internal investigations and compliance reviews.

Our team includes former officials from a wide range of law enforcement and regulatory agencies, including the Department of Justice (DOJ), the Securities and Exchange Commission (SEC), the Commodity Futures Trading Commission (CFTC), Federal Bureau of Investigation (FBI), the Department of Homeland Security (DHS), the Department of the Treasury, the Internal Revenue Service (IRS), the Federal Trade Commission (FTC), the Federal Energy Regulatory Commission (FERC), the Department of Treasury’s Office of Foreign Assets Control (OFAC), the Department of State’s Directorate of Defense Trade Controls (DDTC), the Department of Commerce’s Bureau of Industry and Security (BIS), and the New York County District Attorney's Office.

We conduct independent investigations for boards and board committees, and internal investigations for public and privately-held companies, universities, and government institutions. Steptoe lawyers provide crisis management advice and we work with our clients to help them avoid or limit exposure before federal and state government agencies in related litigation, and in the press. In addition, in connection with an investigation, our lawyers frequently design and implement remedial and preventive compliance measures, enhance compliance programs and controls, and provide business and governance counseling and guidance.

We have offices around the world that extend our reach for global investigations and allow us to manage data privacy issues when conducting investigations that require us to collect and review documents overseas and interview witnesses in foreign countries.

Our judgment and deep law enforcement and government experience give us the ability to scope investigations properly and economically for our clients. At Steptoe, we don't do "runaway" investigations, and we are sensitive to the disruptions and collateral consequences that such investigations may cause. Our team excels in conducting complex, multijurisdictional investigations efficiently and cost-effectively.

We are recognized by leading legal directories and publications – including Chambers USA, Chambers Global, The Legal 500, and Law360 – for our preeminence in investigations and corporate criminal defense.

Noteworthy

Global Investigations Review (GIR) 100, Top 30 Firms for Investigations Worldwide (2015-2023)
Chambers Asia-Pacific, Corporate Investigations/Anti-Corruption (International Firms), Greater China Region (2022-2023)
Chambers Asia-Pacific, International Trade/WTO, Asia-Pacific Region (2009-2025)
Chambers Greater China, Corporate Investigations/Anti-Corruption (2024-2026)
Chambers Global, Corporate Investigations: Anti-Corruption, Global (2015-2018, 2022, 2025-2026)
Chambers Global, Corporate Investigations/Anti-Corruption, (International Firms), China (2021-2026)
Chambers Global, Corporate Crime & Investigations, US (2017-2026)
Chambers Global, Investigations & Enforcement (International & Cross-Border), US (2020-2026)
Chambers Global, FCPA, US (2017-2025)
Chambers USA, Corporate Crime & Investigations: The Elite, Nationwide (2021-2026)
Chambers USA, Litigation: White-Collar Crime & Government Investigations, DC (2014-2026)
Chambers USA, Litigation: White-Collar Crime & Government Investigations, IL (2025-2026)
Chambers USA, Litigation: White-Collar Crime & Government Investigations: The Elite, NY (2026)
Chambers USA, Litigation: White-Collar Crime & Government Investigations, TX (2025-2026)
Legal 500 US, Dispute Resolution: Corporate Investigations and White-Collar Criminal Defense: Advice to Corporates and Advice to Individuals (2012-2026)
Legal 500 Latin America, the International Firms: Compliance and Investigations (2026)
China Law & Practice, Shortlisted, International Firm of the Year: Regulatory & Compliance (2018, 2021-2022)
China Business Law Journal, China Business Law Award: Corporate Compliance (2019-2026)

Professionals

Evan T. Abrams

Evan Abrams counsels financial institutions, multinational corporations, and individuals on a variety of international regulatory and compliance matters. He regularly advises clients on issues related...

Partner

Anti-Money Laundering, Economic Sanctions, Financial Services, Artificial Intelligence

Washington, DC
+1 202 429 3052

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Ida Adibi

Ida Adibi focuses her practice on commercial litigation, investigations, and criminal defense. She has worked on all phases of civil matters, from case origination through trial. As a consequence, she...

Associate

Commercial Trials & Litigation, Campaign Finance & Political Law, White-Collar Defense, Independent & Internal Investigations

Washington, DC
+1 202 429 3034

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Yousuf Aftab

Yousuf Aftab is a partner at Steptoe's New York office, where he focuses on business and human rights and sustainability law. With a rare depth of practical experience, Yousuf is renowned for...

Partner

Business & Human Rights, ESG, Climate & Sustainability, Independent & Internal Investigations, White-Collar Defense

New York
+1 212 506 3920

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Lindsay B. Arrieta

Lindsay Arrieta is Of Counsel in Steptoe's Investigations and White-Collar practice, based in the firm’s Washington, DC office. Her practice focuses on advising clients on anti-corruption and...

Of Counsel

Independent & Internal Investigations, Monitorship, Anti-Corruption/FCPA, White-Collar Defense

Washington, DC
+1 202 429 3904

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Myles Ashong

Myles Ashong represents corporate and individual clients in internal and government-facing investigations and white-collar defense matters.His experience spans all phases of government enforcement,...

Associate

Independent & Internal Investigations, White-Collar Defense, Sports Integrity Team

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Rose Beattie

Rose Beattie represents both individual and corporate clients in criminal investigations and prosecutions, criminal appeals, internal investigations, and civil litigation. Her experience includes...

Associate

White-Collar Defense, Independent & Internal Investigations, Commercial Trials & Litigation

Washington, DC
+1 202 429 3033

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Brigida Benitez

Brigida Benitez serves as a strategic advisor to companies, boards, and executives facing corporate crises. She draws on more than 30 years of experience representing clients in high-stakes, complex...

Partner and General Counsel

Independent & Internal Investigations, Anti-Corruption/FCPA, Global Anti-Corruption Insights: FCPA Years in Review, Commercial Trials & Litigation

Washington, DC
+1 202 429 6261

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Iris E. Bennett

Iris Bennett has more than two decades of experience representing companies and individuals in the defense and resolution of criminal and civil investigations by the U.S. DOJ and other U.S. agencies....

Partner

Anti-Corruption/FCPA, Independent & Internal Investigations, White-Collar Defense, Fraud & False Claims Act

Washington, DC
+1 202 429 8125

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Samuel Bloebaum

Samuel Bloebaum is a due diligence analyst in Steptoe's International Trade & Regulatory Compliance Group. He is an experienced researcher and investigator, with a focus on AML/CFT compliance,...

Senior Analyst

National Security & Cross-Border Transactions, Crisis Management, Economic Sanctions, Trade Policy & Negotiations

Washington, DC
+1 202 261 7558

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Anna Bninski

Anna Bninski focuses her practice on internal investigations and commercial litigation. A former judicial law clerk, she has defended corporate clients in arbitrations and taken plaintiff and witness...

Associate

Independent & Internal Investigations, White-Collar Defense, Ethics & Compliance, Commercial Trials & Litigation

Chicago
+1 312 577 1279

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Representative Matters

Conducted an independent review of a global bank’s compliance with SEC rules relating to employees’ use of certain electronic communications platforms.
Conducted an independent investigation on behalf of the City of Baltimore into the largest corruption scandal in the history of the Baltimore Police Department (gttfinvestigation.org).
Conducted an independent investigation for the Special Committee of the board of directors of a public fintech company relating to allegations of fraud in the company’s operations in Africa.
Conducted an investigation on behalf of the Special Litigation Committee of the board of directors of a public biopharmaceutical company involving allegations of financial misstatements, channel stuffing, violations of the Anti-Kickback Statute, retaliation, and other healthcare related issues.
Conducted internal investigations into whistleblower complaints alleging bribery and other misconduct at a global automobile manufacturer.
Conducted an internal investigation for a global motorcycle company into allegations of misconduct in connection with sales and revenue reporting.
Conducted an independent investigation on behalf of a Special Committee of the Board of Directors of Pilot Flying J, the largest travel center and diesel fuel provider in the United States, in connection with allegations that the company defrauded some of its trucking company customers.
Conducted independent AML/Bank Secrecy Act/sanctions compliance reviews for two of the world’s largest cryptocurrency companies.
Representation of a crypto mining company and CEO in responding to a FINRA inquiry and conducting an internal investigation related to compliance issues.
Conducted several workplace culture and misconduct investigations for a large nuclear utility headquartered in the US Southeast – ranging from department-wide assessments to investigations of allegations against single employees and executives.
Conducted an investigation on behalf of a Japanese construction company and its Latin American subsidiary in connection with allegations by the World Bank of collusion and fraud.
Conducted an internal investigation on behalf of a multinational private security contractor in connection with allegations of potential improper payments to government officials in Afghanistan.
Conducted an internal investigation on behalf of a multinational private security contractor in connection with allegations of potential export control violations arising from the export of defense articles from China.
Conducted a multi-jurisdictional internal investigation into alleged FCPA violations in the foreign operations of a publicly-traded offshore drilling contractor and conducted a review of the company’s compliance program. Based on the thoroughness of the Steptoe investigation, both the DOJ and the SEC terminated their investigations without any enforcement action.
Conducted an investigation on behalf of a Japanese laboratory services company and its US subsidiary in connection with potential violations of the Anti-Kickback Statute and False Claims Act.
Conducted an internal investigation on behalf of a Japanese construction machinery repair company and its US subsidiary in connection with allegations of misappropriation of trade secrets and unauthorized access to third-party computers.
Conducted an internal investigation on behalf of a Japanese automotive textile manufacturer and its US subsidiary in connection with allegations of accounting irregularities.
Conducted an internal investigation for a government contractor relating to alleged gratuities provided to government officials. Steptoe also conducted a review of, and developed enhancements to, the company’s compliance policies, procedures and employee training programs.
Conducted an internal investigation on behalf of the operator of a major airport into the operations of the airport's transit system.
Conducted an internal investigation for a leading oil field services company, relating to possible FCPA violations arising from alleged payments to government officials in multiple countries in sub-Saharan Africa and Southeast and Central Asia.
Represented a renewable energy investment company’s audit committee in an investigation into certain accounting-related issues raised in a short-seller report.