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Investigations and Enforcement

With the increase of regulatory and legislative change across all industries, internal investigations are increasingly common in most organisations. There can be a range of triggers for internal investigations, including ongoing business monitoring/audits, customer complaints, a whistleblowing report, a requirement by a regulator, or employee fraud.

Internal investigations have become part of good corporate governance, and reinforce the requirement for good culture and conduct by demonstrating that employees will be held accountable for poor behaviour and/or misconduct.

Top three things on the horizon

  1. SFC seeks to widen its enforcement power - On 10 June 2022, the Securities and Futures Commission (“SFC”) published the Consultation Paper on Proposed Amendments to Enforcement-related Provisions of the Securities and Futures Ordinance (“Consultation Paper”) - Read here
  2. The New Draft Bill on the Implementation of the EU-Whistleblower - Directive in Germany Or: You always meet twice! - Read here
  3. Enforcement appears as messages disappear: The perils of personal and ephemeral messaging - Read here


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