Every case and every interview is, of course, different, but many of the basic questions below will be relevant at the outset of most cases. Cover as many of the following points as possible and follow up for more detail as appropriate:
- The full names, job titles and contact information for all persons and entities allegedly involved.
- The details (who, what, when, where, and why) of the allegations.
- The dates or time period of the key events.
- How much money or losses are involved.
- Are there any electronic or paper records that support the allegations? If so, what and who has them?
- The names, location and contact info 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?
Arrange for a follow up interview or email contact with a complainant after you have 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 an initial interview, 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, relevant documents and other witnesses who will testify. Assure the witness that he or she will not be compelled to testify if they are unwilling to do so.)
- What is the complainant’s motive to report? (In most cases, the complainant’s motive is not as important as other factors that may affect his or her credibility.)
- Try to determine if there is any other reason to suspect the complainant’s credibility, such as a personal interest in the transactions, a history of disputes between the parties or a prior criminal record.
As noted above, at this point do not be too concerned about trying to evaluate 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:
Try to obtain as much of the following information as possible:
- The full names, employment and locations of the persons who offered, paid, received or solicited the bribes, and any middle men or facilitators involved.
- How much money was involved in the bribe payments and the corrupt transactions, e.g., a $10,000 bribe to win a $100,000 contract.
- 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 of 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 where the paper or electronic records are located and who has them. Request copies. Ask for emails or other communications regarding the scheme or underlying transactions.
- 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.
See initial-interview-questions-by-scheme and basic advice on how to interview a cooperative witness.