A case currently working its way though courts in the U.K. considers, and thus far, has limited, privilege in the context of internal investigations. Meanwhile, across the pond in the United States, broad privilege protections have been applied when companies conduct internal investigations led by in-house counsel.

These are just two cases in as many jurisdictions, but they highlight the patchwork of decisions that govern attorneys’ communications, leaving many in-house counsel who work across borders to ask: How can I protect my privilege?

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