The General Counsel of a company based in London receives a call from the CFO regarding unusual product returns from South Asian customers and a whistleblower complaint about irregular business practices. The company is scheduled to release quarterly financial results in 10 days and trades on the NYSE. The General Counsel calls outside counsel seeking advice on how to determine if unlawful conduct occurred, whether to conduct an investigation, who should lead it, and when regulators must be notified. Conducting an international investigation presents challenges regarding foreign evidence, languages, laws, and privileges. The response will address preliminary considerations of jurisdiction, procedural matters like who leads the investigation and collects evidence abroad, and potential barriers and disclosure obligations.