Where conduct crosses borders, multiple authorities may investigate, and managing the relationships is as important as the underlying facts.
Coordination among authorities is now routine, including joint investigations and coordinated resolutions. Assume that what is said to one is known to the others.
Sequencing. Different limitation periods, different evidentiary standards, and different approaches to self-reporting credit. Disclosing to one authority and not another rarely remains contained.
Anti-piling-on. Several authorities apply policies crediting penalties paid to other regulators for the same conduct, which makes coordinated resolution valuable and requires the organisation to raise it.
Privilege differences. In-house counsel privilege is not recognised in several jurisdictions; litigation privilege has different thresholds; and material seized in one country may be used elsewhere.
Employee interviews in jurisdictions with strong employment protections require different warnings and, in some, representation rights.
Data transfer constraints on moving evidence between jurisdictions.
Local counsel in each relevant jurisdiction from the start, coordinated by one lead so the organisation speaks with one voice.
Public statements must be consistent across jurisdictions and must account for disclosure obligations in listed markets.