Every case and every interview is, of course, different, but the questions below should be asked at the outset of virtually every case. Cover as many of the following points as possible and follow up for more detail on each as appropriate:
- The full names, job titles and contact information for all persons and organizations allegedly involved.
- The details (who, what, when, where, why and how much) of the allegations.
- The dates or time period of the key events.
- How much money or losses are involved.
- Are there any records or documents that support the allegations? If so, what and who has them? Ask for electronic and paper copies.
- The names, location and contact information of other persons who might know of the wrongdoing and be willing to discuss it.
- Are there other similar transactions? If so, get the details, and find out who knows about them.
- How does the complainant know about the allegations? If from other persons, who and where are they?
Follow up interviews or email contact should be arranged with all complainants after the investigator has had time to do a quick initial investigation. If the complainant is being interviewed by telephone, and wants to remain anonymous, schedule a time for the witness to call in for a follow up interview.
Other potentially useful questions:
Other potentially useful questions to ask in the initial interview include, depending on the circumstances, include:
- Is the scheme currently on-going? If so, do the subject(s) know of the complainant’s report? (This helps to determine whether a covert investigation would be feasible.)
- Will the complainant agree to testify or sign a statement? (Many will not, but their information is still useful to identify leads, documents and other witnesses who will testify.)
- What is the complainant’s motive to report? (In most cases, the complainant’s motive is not as important as his or her credibility.)
- Try to determine if there is any reason to suspect the complainant’s credibility, such as a personal interest in the transactions, a history of disputes between the parties or a criminal record.
As noted above, at this point do not be too concerned about trying to evaluate or speculating on the complainant’s motive or credibility. If the information appears to be plausible, test it against other information in the case and proceed on that basis.
Initial questions about corruption allegations:
These questions might be helpful in cases involving alleged or suspected bribes, kickbacks or financial interests by project officials:
- Ask for the full names, job titles and locations of:
- The persons who solicited or received the bribe and the persons or companies that paid the bribe, or offered to do so.
- Any agents, middlemen and subcontractors involved in the payments.
- Try to get as many details as possible of the alleged bribes, including:
- How much money was involved in the bribe payments and the overall transactions?
- What the bribe payments were for, for example, to be selected, to get a contract amendment, to be paid promptly, etc.?
- How the payments were made – by cash, wire transfer or check, or in the form of goods or services – and how the payments were recorded – for example, as a “consulting fee” or commission or miscellaneous expenses. Ask who was involved in these transactions.
- Try to identify the account (or at least the bank) or source of funds from which the payments were made, and the bank or accounts to which they were made.
- Ask about documentation of the bribe payments and the evidence corrupt influence. This could include, of course, bank account records, wire transfer receipts, or false invoices and receipts to disguise the payments. Evidence of corrupt influence could include documentation showing inflated pricing, acceptance of poor quality work, approval of unnecessary change orders, etc. Ask who has the records and where are they? Request copies.
- Get the names and location of other persons who might know of the scheme, such as former employees or competitors of the bribe payer (who also might have been approached for bribes), associates or subordinates of the bribe taker.