Internal Investigations

Barton employs attorneys from some of the most prestigious law enforcement agencies in the country. Barton’s Internal Investigations team consists of former prosecutors of the SDNY; Manhattan, Bronx, and Queens District Attorney’s Office; and a New York Detective and U.S. Special Agent.

Barton regularly conducts corporate internal investigations at the request of clients concerned with an existing or potential internal issue. Our team works tactfully and thoroughly, seeking to minimize exposure and provide timely solutions for the matter at hand, whether it be suspected criminal activity, regulatory violations, SEC or FINRA violations, money laundering, fraud, embezzlement, corporate espionage, F.C.P.A. insider trading, trade secret theft, or other financial-related malfeasance or illegality.

As a result of the collective Barton experience, our investigations are done professionally, with regard to the requisite evidentiary issues and potential client strategies. If there are issues to be found, the Barton team is very effective at identifying them. We conduct internal investigations at the independent request of clients and also as a supplement to already on-going government investigations.

Barton understands the significance of the identification and, at times, self-reporting of issues identified internally in certain industries. We regularly work to mitigate exposure to the client that may result from investigation findings. At times, our internal investigations identify criminal or regulatory violations. If criminal activity or issues pertaining to law enforcement are found, Barton is adept at liaising with the federal, state, and local authorities to minimize the impact on the client, and we can also provide clients with assistance to resolve the issue.

Barton has successfully negotiated cooperation agreements and other non-criminal sanctions for self-reporting of client issues after our internal investigation has identified them. Barton is committed to handling these highly sensitive internal investigations as discreetly and efficiently as possible, while also recommending the proper recourse once the investigation has concluded.

Work in this Area

Internal Investigations

Representative Matters
  • Represented Hedge Fund in Insider Trading Investigation
    • Represented a hedge fund in parallel DOJ and SEC investigations into insider trading; conducted numerous interviews and managed document review of internal investigation; worked closely with the client to achieve a highly favorable settlement with the SEC; was involved in every aspect of the external and internal investigations.
  • Led Internal Investigation into NYC Hospital System Breach
    • Represented a New York City hospital system by leading an investigation into breach of patient information from five hospitals and disclosure onto five Internet search engines, while also coordinating breach response and reporting.
  • Led Investigation into Global Theft of Trade Secrets
    • Led investigation into and provided counsel and coordination for response to theft of trade secrets from a multi-national oil equipment manufacturing corporation, where theft originated in eleven countries.
  • Represented Companies in SEC Matters
    • Represented companies in matters before the Securities and Exchange Commission (SEC), including responding to subpoenas, representing clients at witness interviews and depositions, drafting and defending Wells submissions, preparing for trial, presenting results of internal investigations to the SEC, and conducting settlement negotiations.