Independent judgment. Disciplined fact-finding. Practical legal guidance.
Organizations confronting allegations of misconduct, compliance concerns, internal disputes, or other sensitive matters need more than someone who can gather facts. They need investigators who understand how to identify what matters, test competing accounts, protect sensitive information, assess legal and institutional risk, and provide decision-makers with clear and defensible findings.
Compass Rose Legal Group conducts independent, attorney-led internal and corporate investigations for companies, boards, executives, nonprofit organizations, and other institutions confronting sensitive or high-stakes matters.
In these engagements, Compass Rose serves as the independent investigator, retained by the organization to determine the facts — not as counsel to any individual under investigation.
Our investigations practice draws upon decades of experience conducting and overseeing complex investigations within the federal government, intelligence community, law enforcement, and private practice. That experience allows us to approach internal investigations with the independence, discretion, and analytical rigor ordinarily associated with government oversight, while remaining focused on the practical needs of the organization.
Matters We Investigate
The firm can conduct or assist with investigations involving:
- Allegations of employee or executive misconduct;
- Workplace complaints, including discrimination, retaliation, harassment, and hostile-work-environment allegations;
- Whistleblower complaints and allegations of retaliation;
- Fraud, waste, abuse, and misuse of organizational resources;
- Conflicts of interest and breaches of fiduciary or professional obligations;
- Ethics and compliance concerns;
- Government contracting and procurement issues;
- Mishandling or unauthorized disclosure of sensitive information;
- Security, clearance, and national-security-related concerns;
- Allegations involving senior leadership or other sensitive personnel;
- Internal-control and governance failures;
- Matters involving potential regulatory, inspector general, congressional, or law-enforcement scrutiny; and
- Other circumstances in which an organization requires an independent and credible factual assessment.
We also assist organizations in assessing allegations before commencing a full investigation. This includes determining the appropriate scope, identifying potential legal and institutional risks, preserving relevant evidence, and evaluating whether an independent investigation is warranted.
Independent Investigations
Some matters require an investigation that is demonstrably independent from ordinary management structures.
Compass Rose Legal Group can be retained by boards of directors, board committees, general counsel, senior management, or other authorized decision-makers to investigate allegations involving executives, senior officials, organizational leadership, or particularly sensitive institutional concerns.
Where appropriate, we work with the client at the outset to establish a written investigative mandate defining the issues to be examined, the investigator’s authority, reporting relationships, privilege considerations, and the anticipated investigative product.
Our role is to determine what the evidence supports—not to validate a predetermined conclusion.
Investigative Approach
Every investigation is different. Our methodology is therefore tailored to the nature and seriousness of the allegations, the organization involved, and the purpose for which the investigation is being conducted.
An investigation may include:
- Defining allegations and investigative issues;
- Developing an investigative plan;
- Identifying and preserving relevant evidence;
- Reviewing emails, records, policies, communications, and other documentary evidence;
- Conducting witness and subject interviews;
- Testing witness accounts against documentary and other evidence;
- Developing timelines and evidentiary chronologies;
- Identifying corroborating and contradictory evidence;
- Assessing applicable policies, regulations, contractual requirements, and legal standards;
- Coordinating with forensic, technical, financial, or other specialists when necessary; and
- Preparing findings and recommendations for organizational decision-makers.
We place particular emphasis on contemporaneous evidence, careful witness interviewing, corroboration, and distinguishing established facts from allegations, assumptions, and unresolved questions.
Findings and Reporting
The usefulness of an investigation ultimately depends upon the quality of its findings.
Depending upon the engagement, Compass Rose Legal Group can provide verbal briefings, investigative memoranda, executive summaries, evidentiary chronologies, or comprehensive written reports.
Our reports are designed to allow decision-makers to understand not simply what we concluded, but why. Where appropriate, findings identify the evidence supporting the conclusion, significant contrary evidence, credibility considerations, and issues that could not be resolved based upon the available record.
We can also identify compliance, governance, policy, or internal-control issues revealed during an investigation and advise the organization regarding appropriate remedial measures.
Investigations Involving Government or National Security Issues
The firm is particularly well positioned to handle investigations that intersect with the federal government.
Our attorneys have substantial experience involving the intelligence community, inspectors general, congressional oversight, federal law enforcement, security clearances, whistleblower matters, and sensitive government information.
That experience can be particularly valuable when an internal matter carries the possibility of external scrutiny—including inquiries from an Inspector General, Congress, a federal agency, law enforcement, or another oversight body—or involves classified, controlled, proprietary, or otherwise sensitive information.
In those circumstances, an internal investigation must often accomplish two objectives simultaneously: determine what happened and ensure that the organization’s response does not unnecessarily create additional legal, regulatory, reputational, or institutional risk.
Experience That Informs Our Work
The firm’s investigations practice is grounded in the backgrounds of its attorneys.
Andrew P. Bakaj is a former Central Intelligence Agency officer and former federal investigator. His work has involved national security, intelligence oversight, whistleblower matters, and complex investigations concerning government institutions and senior officials. His practice has included representing individuals and organizations in matters involving Inspectors General, congressional oversight, federal agencies, and other sensitive investigative proceedings.
I. Charles McCullough III served as the first Senate-confirmed Inspector General of the Intelligence Community. Over a career spanning federal law enforcement, intelligence, and oversight, he held senior investigative and leadership positions involving the Federal Bureau of Investigation, the National Security Agency, the Department of the Treasury, and the Intelligence Community. As Inspector General, he was responsible for independent investigations, inspections, audits, and reviews involving some of the government’s most sensitive programs and institutions.
Together, the firm’s partners bring experience from multiple sides of the investigative process: conducting investigations, overseeing investigators, assessing allegations, working with whistleblowers and witnesses, navigating government oversight, and representing individuals and organizations whose conduct is under scrutiny.
That perspective informs how we conduct investigations today.
Counsel When the Stakes Are High
An internal investigation is rarely an end in itself. Its purpose is to give decision-makers reliable information upon which they can act.
Compass Rose Legal Group approaches investigations accordingly: independently, discreetly, and with an understanding that investigative decisions made today may later be examined by employees, boards, regulators, courts, Inspectors General, Congress, law enforcement, investors, or the public.
Our objective is to establish the facts, identify the relevant legal and institutional considerations, and give the client a sound basis for deciding what comes next.
To discuss an internal or corporate investigation, contact Compass Rose Legal Group.
