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This is the third in a three-part series about the challenges facing lawyers engaged in internal investigations. Part I focused on the special considerations attendant to an attorney’s representation of a corporate entity in these matters, and Part II discussed best practices with respect to fact-finding efforts. This installment focuses on a key concern of counsel as an internal investigation nears completion – namely, how to advise a client with respect to the possibility of making a disclosure to the government about the results of the internal investigation.

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