Internal investigations are not new in human resources. Employee complaints of sexual harassment or discrimination, or of retaliation for making these complaints, have provided healthy fodder for internal workplace investigations for many years.

In the era of the whistleblower, however, things have gotten much more complicated. Complaints of sexual harassment and discrimination are being replaced by, or perhaps coupled with, complaints of retaliation for blowing the whistle on alleged illegal conduct, such as financial fraud or violations of complex regulatory schemes to which the employer is subject.

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