Playbook for global investigations

In today’s interconnected global economy, businesses operate across multiple jurisdictions, and transactions move across borders in an instant. While this creates opportunities for growth, it also opens new avenues for misconduct. Criminals exploit these complexities to commit fraud and other financial crimes, leaving organizations vulnerable to risks that span continents.

Managing an incident in this environment is inherently complex. From the moment an issue is identified through investigation, remediation and disciplinary action, organizations must navigate a maze of legal, regulatory and cultural considerations. Each step demands precision and consistency to ensure compliance and protect reputation.

Global investigations typically follow the same foundational principles as domestic inquiries but with added layers of difficulty. Investigators must contend with cross-border data privacy laws, language barriers and differing standards of proof. Coordinating stakeholders across regions, ensuring adherence to local labor laws and maintaining fairness throughout the process are essential to success.

This e-book brings together insights from RSM’s team of experienced forensic advisors to guide you through these challenges. We explore practical issues investigators face when conducting cross-border inquiries, outline how global investigations typically work, and provide strategies for managing incidents thoughtfully and effectively. Our goal is to equip you with the tools and knowledge to navigate the complexities of international investigations with confidence.

The first step in any investigation is assembling a team. In a global investigation, ensuring a team has the right mix of skills and experience is essential. This requires clearly defining roles and responsibilities. Depending on the particulars of the investigation and the jurisdiction(s) involved, some key considerations when building the team include:

The approach to investigations can vary significantly across jurisdictions. It is vital to have a core team that understands the complexities of international investigations, recognizes the importance of guidance and local support and seeks it out as needed, and can coordinate simultaneous activities in different locations.

Building a team with the right mix of skills involves not only selecting qualified individuals, but also ensuring seamless coordination across jurisdictions. Once roles and responsibilities are clearly defined, the lead investigator must assess the availability of forensic technology specialists who understand cross-border data transfer laws.

Cultural and language considerations are equally critical. Effective interviews and the accurate interpretation of evidence require team members who can navigate local norms and communicate fluently. Where local legal advice is necessary, engaging qualified counsel early can prevent compliance risks and delays.

Assembling a well-structured team and anticipating these complexities will enable the investigation to proceed efficiently, maintain integrity and deliver defensible results. Additional planning for travel, resource allocation and secure collaboration tools will be essential to ensure consistency and accountability throughout the process.

In many cases, a local presence is necessary for effective interviews. Just as in domestic investigations, interviewing is a skill set honed through experience, and interviewers must know how to navigate the questioning to obtain the necessary information.

Understanding the key differences in the legal and regulatory requirements of the jurisdictions within the scope of your investigation is essential. Some of these differences may be clear at the start of the investigation, while others may only become apparent later. It is critical for the investigator to properly assess the legal and regulatory challenges and the potential risks to the investigation.

The investigator must initially assess local investigative and data privacy laws that may affect the investigation and the collection, transfer and processing of data, and seek legal advice when necessary. The following questions can help determine the challenges that may arise during the investigation:

Use of AI tools

In today’s data-heavy landscape, AI is a powerful ally for investigators, but its use requires a careful balance between efficiency and risk management. While AI can accelerate the review of millions of documents across multiple languages, it also introduces significant challenges regarding data privacy and evidentiary integrity. To ensure results remain defensible in court or before regulators, investigators must address the following:

Although investigators can't be familiar with investigative process and legal considerations in every jurisdiction, they should be knowledgeable about the organization's global approach and know where to go for location-specific guidance as needed.

For any multi-national organization, a vital relationship needs to exist between the investigative team and the IT team that has the knowledge, skills and access to manage data across the full international landscape of the organization.

An e-discovery platform is an effective data management tool that can process electronic data and minimize the amount of data that requires review by the investigation team. Many e-discovery platforms have multilingual and translation capabilities that enable investigators working in multiple jurisdictions to remotely access the global investigation’s single repository of electronic information.

AI can reduce the complexity of data analysis by transforming massive datasets into clear insights and narratives. However, AI must be a tool led by humans, not an automated replacement for them. While frameworks like the Five S Model boost efficiency, companies must maintain rigorous skepticism to prevent data leakage, navigate strict international privacy laws and ensure regional cultural nuances are not lost in translation.

Managing legal and regulatory requirements across multiple jurisdictions is fundamental to the integrity of a global forensic investigation. Once the relevant data sources have been identified, the lead investigator must ensure that collection, transfer and review processes comply with local laws while following a consistent methodology. This includes safeguarding personal data, preserving chain of custody and addressing any statutes that may restrict cross-border information sharing.

Additional planning will be required to implement secure storage solutions, maintain confidentiality and meet reporting obligations to regulators or law enforcement. By anticipating these challenges and embedding compliance into every stage of the investigation, the team can minimize risk and ensure that findings are defensible and reliable.

Understanding the cultural and linguistic complexities of a global forensic investigation is important to its success. While some challenges may be evident at the outset, others often emerge as the investigation progresses.

Managing subject interviews across multiple languages and navigating diverse cultural norms requires thoughtful planning to avoid misunderstandings that could compromise the investigation. Local business practices—such as gift-giving or reliance on intermediaries—may appear benign within their cultural context but could be misinterpreted as fraudulent or corrupt by those unfamiliar with the region. Addressing these issues early and incorporating cultural awareness into investigative protocols helps preserve objectivity and integrity throughout the process. Investigators should ask the following questions:

Recognizing and planning for cultural and linguistic challenges is fundamental to building an effective global investigation team. Proper coordination and planning is essential to ensure accuracy, maintain cultural sensitivity and uphold the integrity of the investigation across all jurisdictions.

When conducting a travel and entertainment review in Colombia, the RSM team held numerous conversations with the local management team to discuss what supporting documents had been collected to support reimbursement of the expenses under review. The company allowed employees to request cash advances to pay for expenses incurred from vendors in small towns that required cash payment. Unlike in the United States, it was not uncommon for employees to pay for meals or transportation, such as taxis, in cash to vendors that were unable to provide a supporting receipt. The typical process of validating that the money was spent on business-related travel with a receipt was not possible. This was an inherent risk of the business, and RSM suggested process changes that might reduce the possibility of misuse, such as duplicate reimbursement. Understanding the cultural differences helped the RSM team understand what data gaps might exist.

Every aspect of how data is obtained and processed, including translation between languages, must be considered, especially when legal action is anticipated. Courts and opposing counsel will scrutinize the chain of custody and may challenge any irregularities in the origin or handling of evidence. Even seemingly minor details, such as how a document is translated, can become critical. For example, removing profanity from the translation of emails or altering tone for readability may unintentionally change the meaning of the original content. Such modifications can lead to allegations of evidence tampering or misrepresentation when presented in court.

At an early stage, the investigation team should develop a strategy for updating key stakeholders on the progress of the investigation, particularly when the stakeholders are located in different jurisdictions or time zones.

Additionally, the investigation team should decide how the findings should be reported, including by and to whom. This should be modified as needed throughout the investigation in response to findings and developments, such as a decision to pursue legal action or the determination that a criminal act occurred or regulatory standards were violated. Labor laws in some jurisdictions may require a written report if disciplinary action is to be taken.

Investigators preparing for litigation should ask the following:

Reporting lines and accountability are areas for which organizations can plan ahead. In addition to ensuring the reporting structure complies with relevant laws and regulations, investigators should consider its compatibility with the organization's business and management structure.

Establishing clear protocols for stakeholder communication and reporting is fundamental to the credibility and effectiveness of any investigation. By defining timelines for updates, clarifying escalation procedures for urgent findings and determining the appropriate recipients of reports, the investigation team ensures transparency while safeguarding confidentiality, legal privilege and compliance with privacy laws across jurisdictions.

Early engagement with local counsel, IT specialists and management helps anticipate restrictions on data sharing, reporting obligations to regulators or law enforcement, and labor law requirements tied to disciplinary actions. In cases involving litigation, coordination with outside counsel and expert witnesses, along with multilingual documentation where necessary, strengthens the defensibility of the investigation’s outcomes.

A well-structured reporting strategy—adaptable to evolving findings and responsive to jurisdictional requirements—provides stakeholders with confidence in the process and ensures that the investigation delivers reliable, actionable results.

In one engagement, RSM provided confidential reporting to the integrity team within the parent company. This centralized approach ensured that sensitive findings were initially restricted to a trusted group, safeguarding confidentiality and maintaining compliance with applicable data privacy laws. From this reporting channel, the integrity team developed a general action plan to address the findings. After finalizing the report, the team communicated the plan to the local management teams in the relevant jurisdictions.

In another case, RSM provided a report on the travel and entertainment expenses of a Mexican subsidiary, submitting it in English to management at the company’s U.S. headquarters. RSM also sent it to the Mexican subsidiary’s management for review and input into the action plan. Because some members of the Mexican team spoke English, while others spoke only Spanish, RSM circulated English and Spanish versions of the report to support the review process. Translating a report can take significant time and require language capabilities beyond the use of technology to ensure that the contents are communicated with substantively the same meaning.

Addressing the findings of a global investigation requires careful consideration of roles, responsibilities and compliance obligations across multiple jurisdictions. While some remediation requirements may be evident early, others often emerge as the investigation progresses. It is essential to evaluate the interplay between global and local management, assess gaps in compliance programs and determine whether corrective actions should extend beyond the jurisdiction where the issue originated. Legal defensibility, cultural nuances and regulatory alignment must guide every decision to ensure consistency and sustainability.

The following questions can help organizations navigate these complexities and implement effective remediation measures:

Implementing effective remediation across multiple jurisdictions is vital to restoring compliance and safeguarding organizational integrity. Beyond addressing the immediate findings, the process must ensure that corrective actions align with global standards while respecting local laws and cultural considerations. Remediation includes revising policies, introducing sustainable controls and maintaining consistency in disciplinary measures without compromising legal defensibility.

Clear communication, robust oversight and measurable progress indicators are essential to demonstrate accountability and transparency. By embedding these principles into the remediation plan, organizations can reduce risk, strengthen governance frameworks and reinforce trust with regulators, stakeholders and employees.