Nota Bene Podcast Ep. 175
The 10 Keys to Successful Investigations: A Crossover Edition of the Fraud Eats Strategy (Scott Moriz) and Nota Bene (Scott Maberry) Podcasts
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Listen to the original podcast released October 8, 2025 here:
https://www.sheppard.com/notabene-650
In this special crossover episode, Scott Moritz, President of White Collar Forensic LLC and host of the Fraud Eats Strategy, and Scott Maberry, host of the Note Bene, discuss important considerations in internal investigations and how integrating each into your process can improve efficiency and lead to better and more consistent results.
About Scott Moritz
Scott Moritz is the president of White Collar Forensic LLC.
Based in the New York City Metropolitan area, with expertise performing assignments throughout the U.S. and cross-boarder experience, he conducts complex investigations of white-collar crime, corruption, and money laundering, from inception to the pursuit of avenues of financial recovery, as well as root cause analysis and remediation of internal controls and compliance frameworks. Scott frequently oversees large investigations teams and complementary workstreams of eDiscovery, computer forensics, forensic data analysis, technical accounting, expert testimony, surveillance, witness interviews, cyber incident response, executive protection and crisis management practitioners.
Prior to embarking on his 29 year private sector career, Scott served as an FBI Special Agent in the Memphis and New York field offices, where he investigated white collar crime, organized crime and international money laundering.
About Scott Maberry
Scott Maberry is an international trade lawyer at Sheppard Mullin. He counsels clients on global risk, international trade, and regulation.
Scott’s practice includes representing clients before the U.S. government agencies and international U.S. Department of Treasury’s Office of Foreign Assets Control (OFAC), the Department of Commerce’s Bureau of Industry & Security (BIS), the Department of Commerce Import Administration, the Department of Homeland Security (DHS), the Department of State Directorate of Defense Trade Controls (DDTC), the U.S. Department of Justice (DOJ), the International Trade Commission (ITC) and the Committee on Foreign Investment in the U.S. (CFIUS). He also represents clients in federal court and grand jury proceedings, as well as those pursuing negotiations and dispute resolution under the World Trade Organization (WTO), North American Free Trade Agreement (NAFTA) and other multilateral and bilateral agreements.
A member of the World Economic Forum Expert Network, Scott also advises the WEF community in the areas of global risk, international trade, artificial intelligence and values.
Transcript:
Scott Moritz:
Welcome to this special crossover edition of the Fraud Eats Strategy and Nota Bene Podcast, during which we'll examine the important considerations of internal investigations and how assimilating them into your process can make investigations much more efficient and lead to better and more consistent outcomes. I'm Scott Moritz, President of White Collar Forensic. We're together with our partners from Integrity Risk International. We assist clients and their outside counsel in managing their response to white collar crime, money laundering and bribery incidents, assist in the pursuit of financial recoveries and help fix the things that were exposed as broken along the way.
Scott Maberry:
And I'm Scott Maberry. I'm an international trade lawyer at Sheppard Mullin in Washington, D.C.
Scott Moritz:
Well, thank you, Scott. You and I have been talking about this for a while, and I think we're in violent agreement that investigations don't always go according to plan and sometimes there's no plan at all. And even if there's a plan or there isn't a plan, they rarely follow a straight line. And when the unexpected happens, the investigative team really needs to make adjustments on the fly. And another factor that often comes into play is time pressure. There's pressure to start the investigation and demonstrate progress, make regular reports to leadership, and to bring them to an end just as quickly. And organizational leadership doesn't necessarily understand or accept the fact that there's no way to predict outcomes or the length of time an investigation may require. But following a defined methodology will help create efficiencies and create more consistent results.
And to help organizations shape their investigative process, Scott and I have developed a list of eight musts and two nice-to-haves when carrying out internal investigations. My co-host Scott hosts his own podcast, Nota Bene, a bi-monthly series for multinational businesses providing insights on international legal and policy developments. Nota Bene is Latin for note well, and noting well is something that every internal investigation should really strive for. Scott is an international trade lawyer in Sheppard Mullin's governmental practice. He's a member of the World Economic Forum Expert Network where he advises the WEF community in the areas of global risk, international trade, artificial intelligence and values. Scott's also a founding member of the Sheppard Mullin Organizational Integrity Group. He lives and works in Washington, D.C. Scott counsels and defends clients and in civil and military export controls, the Foreign Corrupt Practices Act, anti-terrorism national security, economic sanctions, anti-boycott controls, anti-money laundering, the Foreign Agents Registration Act, trade remedies, countervailing duty matters, and foreign direct investment controls and customs law. He also represents sovereign and corporate clients in negotiations and dispute resolution under multilateral and bilateral international agreements.
Scott represents clients before the U.S. Department of Treasury, Office of Foreign Assets Control, the Department of Commerce, Bureau of Industry and Security, the Department of Commerce Import Administration, the Department of Homeland Security, Department of State Directorate of Defense Trade Controls, the U.S. Department of Justice, International Trade Commission, CFIUS, federal courts and grand jury proceedings, multilateral and bilateral dispute resolution panels. That was a mouthful. Welcome Scott. I'm excited to be doing this first ever joint episode with you and Nota Bene.
Scott Maberry:
I'm grateful to be here with you and my friend Scott Ritz is President of White Collar Forensic LLC. It's based in New York City with expertise in performing assignments through the United States and extensive cross-border experience. He performs complex investigations of white collar crime, corruption, and money laundering from inception through to pursuing avenues of financial recovery, the performance of root cause analysis, and the remediation of internal controls and compliance frameworks. He has compliance and investigative domain experience in anti-bribery and corruption, ethics and compliance, anti-money laundering and fraud risk management. Scott often oversees investigative teams and complimentary work streams of e-discovery, computer forensics, forensic data analysis, technical accounting, expert testimony, surveillance, witness interviews, cyber incident response, executive protection, and crisis management practitioners. Prior to embarking on his 29-year private sector career, he served as an FBI special agent investigating white collar crime, organized crime and international money laundering, and he served in the Memphis and New York field office of the FBI. Welcome Scott.
Scott Moritz:
Thank you. So it's fair to say that the two of us are investigations nerds having investigated thousands of matters between us. And given that combined experience, it seemed like a podcast episode in which we share musts and best practices, it seemed like the obvious choice. So let's just jump right in. By the way, we've been struggling with what to call one another since we're both Scott. In fact, we're both Scott M, so both are not helpful. So we're just going to go with last names. Scott Squared seems a little too cringey. So topping our lists of musts is the attorney-client privilege and the attorney work-product doctrine. As a non-attorney, I still find it surprising when the suggestion of performing an internal investigation at the direction of counsel is frequently met with resistance. Can you explain why investigation should be directed by legal counsel so that the allegations, scope and findings are all considered attorney work product?
Scott Maberry:
Sure, and that's the default typically. It's not a hard and fast rule, and sometimes there are good reasons not to have the lawyers overseeing everything. But typically what we want to do when we're digging into issues that might create a record of wrongdoing or potential wrongdoing or any kind of record that we want to keep secret from third parties, the attorney-client privilege and the related work-product doctrine are really important. They're not absolute protections, but if you can get that protection, you want to have that protection. So if the attorney is overseeing the work, if the attorney is conducting the work, the material that's produced in the work is protected under the attorney-client privilege.
Additionally, communications between the attorney and their client for purposes of providing legal advice, that's also protected. And a little further out on the spectrum of protection is the material that's protected under the work-product doctrine. And that is that if an attorney directs the work to be done for the purposes of providing legal advice, then work done by non-attorneys can be protected.
And the way the protection works is that if a third party outside the attorney-client relationship requests information or subpoenas information or demands information, if it's privileged information that's usually, in the best world, protected from disclosure.
Now the protection of the work-product doctrine and the attorney-client privilege varies from jurisdiction to jurisdiction around the United States, and it varies widely between the United States and other countries. But suffice it to say, without getting into a lot of detail on that, that having the protection is better than not having the protection. And in order to have the protection, you've got to do some very specific things to maintain the attorney-client privilege. Our first of our two nice-to-haves on our list is to have an investigative plan or an investigative protocol. Scott, what are the benefits to an organization when their investigations are guided by a written plan that's set out before the thing ever happens?
Scott Moritz:
Well, thanks Scott. Yeah, at the top of the episode, we talked about how time pressure is often a factor in internal investigations. Leadership wants to see things resolved quickly. There may be external forces such as law enforcement or regulators that have a rooting interest in a timely investigation and having an investigative plan, one of the benefits of having an investigative plan is there isn't time lost associated confusion, particularly if it's a company that maybe hasn't had a great deal of experience conducting internal investigations. There's a lot of open questions including who's going to be on point inside the organization? What skillsets do we have inside the organization that could be of utility? And where are we lacking in skillsets? Having an investigative plan allows you to kind of be introspective, looking realistically at the skillsets that you have and those that you need to maybe supplement with outside service providers.
Another benefit of those kind of introspective processes is you identify gaps in your capabilities and you can proactively identify resources that you can pull on if you ever need them. And so that enables you to respond quickly.
I think another really important thing is investigations tend to have themes. Some have to do with maybe financial reporting, others might have to do with the strictures around protecting your most sensitive data. So some of what dictates who the internal stakeholders should be and who should preside over that internal investigation goes to those disciplines. So having a plan allows you to figure out, well, who should be calling the shots? And I think another really important factor where a plan can be really beneficial is sometimes investigations result in litigation. Wrongful termination is a common example, when someone is fired for cause as a result of an investigation. The ability to demonstrate that you executed on a consistent and repeatable investigative process will go a long way toward countering any arguments that you acted unreasonably or you were being arbitrary. You can just point to that protocol that you followed and how you followed it.
Scott Maberry:
Yeah, that's a really great way to look at it.
Scott Moritz:
So the planning process and prior experience with internal investigation often lead to the identification of different information sources that exist within the organization, which is so important. And as importantly, who can grant you access to that information and the various ways that those enablers can be reached during and after business hours because the need for an investigation doesn't always occur when it's most convenient. Sometimes these things break at the worst possible time and the ability to connect with people at whatever time of day and whatever day of the week is very important. So what are some of the atypical information sources that have come into play in some of your investigation, Scott? And why is knowing all of the company's data sources and how to access them so important?
Scott Maberry:
Well, the answer is that data can be anywhere. And nowadays it's everywhere. And any one piece of it can be really important to the investigation. And if you don't know where everything could be residing, you don't know where to search and you're not as likely to find the important key facts in your investigation. So one of the first things we do in any investigation, and you do too, is we make sure that the email servers are protected, that people get a notice not to lose, alter or destroy any documents or any records. We do the same thing with hard copy records, and sometimes we do the same thing with other server-related data.
The more atypical areas, the one that comes up the most often in my investigations now is Slack. There are a number of organizations that communicate where if you talk to anybody within the organization and ask them how they communicate with each other, it's over Slack. And so capturing that data can be really important, figuring out who has access. Similarly, any other messaging services.
Also social media is really important. The company social media account is going to be often an important piece of the puzzle as are the social media accounts of particular witnesses or other people who you're going to be interviewing in the matter. Those are the common atypical data sources that are arising in my cases. What about your case?
Scott Moritz:
Well, I had an interesting case recently in which a manufacturing plant was in receipt of information that their contract laborers that works through a third-party company were routinely overstating straight time and overtime and were over-billing by millions of dollars just at one plant. But was really interesting about this plant facility is that it had an access control system, you have those access cards that enable you to get inside the secure perimeter of a building. In this instance, card holders required not just to swipe in, but also they had to swipe out. And that was such critically important information because we had two distinct data sources that we could compare the time keeping system that people were recording their hours in and the access control card that showed indisputably when someone arrived and when they departed. And what was interesting about this case is we actually debunked the allegations based on what we saw in the access control system. So it was, I think, so helpful to have an understanding of the universe of data sources that are available to you because you never know which one's going to become relevant.
Scott Maberry:
And your head of security might have access to that, but you need to know that, you need to know how to get a hold of security. It might be the head of security at the local plant, which might be a different person. So going to your point, that's a really important thing to know in advance and it's a good thing to kind of start gathering as you're putting together your investigative protocol.
Scott Moritz:
Yeah, absolutely.
Scott Maberry:
Well, our second nice-to-have is related, which is it's creating a standing investigations committee. So since investigations tend to emanate from different organizational domains, they have both common elements and then some things that are specific to the organizational domain or the business unit or whatever's being investigated. So knowing the different constituencies who tend to need investigations will point you to what different organizational functions that might need to be represented on the standing investigations committee. So in your experience, what are those constituencies and what's the benefit of creating an investigations committee inside the company?
Scott Moritz:
So I think it really kind of goes back to a certain extent, the same rationale of why it's useful to have a plan is the ability to do things consistently with the understanding that these different constituencies, there may be some variance that has to do with that business unit or the subject at hand. So a human resources investigation might have certain elements that differ from a network intrusion investigation or a financial crime investigation, but there's also commonality. And that standing committee I think is such a useful organ for a variety of reasons. One, of course is to make sure that the other groups have the benefit and the insights that come from internal investigations that may be occurring outside of their primary sphere of influence.
And also just too, kind of ways of sharing maybe some of the pain points that they experienced with an eye toward making things better and perhaps even addressing shortcomings in the control environment, been identified by one group so that other groups won't have the same experience and have to keep repeating itself before they address any kind of shortcoming that might have been exposed by one group.
So separate but related to the topic of standing investigations committee is the concept of when to involve other skillsets and disciplines in your investigation. So what are some of the drivers that dictate when to introduce any additional disciplines and subject matter experts? And what are some important considerations when adding to the team, especially when an investigation is already underway, Scott?
Scott Maberry:
You might come across subject matters that you need expertise in. So for example, an investigation that I'm directing, if there's any accounting that needs to be done, you don't want me doing the accounting. Just for reasons of comparative advantage, there's someone who's better at accounting out there than I am at it relative to what they could do as an investigator and what I can do as an investigator. So there's this subject matter consideration for that.
Another example might be if we need to understand the specific data themselves. So we tend to do a lot of export control investigations and some of the determinations of whether an article or a piece of technical data requires an export license are highly, highly technical. And so sometimes we need to have an engineer help us interpret software or code or images. So you might need that kind of subject matter expertise.
The main point is that as the investigation moves along, there may come a time when you need to bring somebody new into the investigation and have their expertise kind of help you on the investigation. And that brings in a question again of the attorney-client privilege because sometimes it might be tempting to have somebody outside the lawyer team grabbing that person and asking them a bunch of questions and generating a lot of record. And if that isn't done specifically at the direction of counsel, you may be foregoing an opportunity to protect the information that might be generated through that.
Scott Moritz:
Really important point.
Scott Maberry:
Now, although investigations are best performed covertly, like often our fondest wish is to just get in, get it done, get out. This is especially true during the early part of the process, the existence of the event investigation and the problem that gave rise to the investigation sometimes erupts in a very public way. It's important to consider a plan for when an investigation becomes public knowledge. So how important is it to designate who will speak to the press, et cetera, in determining what to say and what not to say?
Scott Moritz:
Well, I think it's critical. It's a question I ask every time I'm meeting with an organization that has a need for an internal investigation. Do you have a relationship with an outside crisis communications firm? Do you have people in-house that act as press spokespersons that are well-suited to front the press in a crisis? Does your CEO or a member of the executive team have crisis communications training? Because absent sort of having thought that through in advance, it kind of defaults to the CEO or maybe the head of the local business unit. And that doesn't necessarily put you in the best footing if that person is not prepared or has not been in that situation before. And public statements that can be either premature or that perhaps commit the company to a certain timetable or level of transparency that isn't appropriate, it may actually compromise the investigation or things like privilege is not a small consideration.
So thinking about it, I think it just all goes back to sort of like, hey, if you thought about this before it happened, you're going to make much better decisions. And designating who speaks to the press is at the very top of the list, especially when you've got maybe an existential crisis that your company's in the middle of, those public comments, those first 24 to 72 hours can really set the tone positively or negatively.
Scott Maberry:
Absolutely.
Scott Moritz:
So Scott, as you know, some investigations involve confidential or anonymous whistleblowers, which the many economic incentives exist for whistleblowers now, the frequency of cases that originate with whistleblowers seems likely to increase as a result of those economic incentives. So with all of that, what are some guidelines and advice on how to interact with whistleblowers, build trust and protect them from being retaliated against?
Scott Maberry:
One of your first legal considerations is that it is absolutely unlawful to retaliate against a whistleblower for bringing to light some misdeed of the company or some of its personnel. So you've got to be really careful in dealing with anybody like that. It seems like clockwork too. I'm sure you've seen this in your investigations. It often happens that that person's either up for a promotion or undergoing some disciplinary action or getting ready to be fired, and that's the time that the investigation comes up. So you have to really manage any of those processes really carefully, and that means making sure that you're completely aligned among the HR team that's dealing with that person, and the investigative team that's dealing with the investigation and the overall legal advice for the company.
Another consideration for whistleblowers is that sometimes you don't know who it is and you've got to assume that it's somebody in the company and that you don't know who it is. Sometimes, very importantly, you don't know whether there's only one. And a few times in investigations we've been caught unawares when we're assuming that there's just one person feeding information to the government in an investigation that we're internally investigating on a parallel track. Sometimes there's more than one.
The worst assumption you can make is that nobody's talking to the government outside of your circle. Typically, in a kind of big existential case like this, there is somebody communicating with the government and typically you're not going to know who it is. Often that person really is acting adversely to your interests or to your company's or your client's interests. And you have to be able to manage that tension as well because very often that internal whistleblower is being compensated as you suggest or stands to be compensated for blowing the whistle on bad acts is also being pressured by the government to give more and more and more information, some of which may be outside the context of what's being investigated. So you've got to make sure you're kind of aware that the scope of the investigation could creep just because somebody in the government's getting information from inside that you're not aware is going out there.
The last thing I want to say about whistleblowers is even when the whistleblower comes through your normal channels, let's say you've got a hotline and somebody calls up the hotline and says, "Here's a tip. Somebody's doing something, we need you to look into it." Then I might get a chance to find out who that person is, then I might get a chance to interview that person. And when we're interviewing that person, one temptation that companies very often have is to guarantee that person confidentiality. "We'll keep you out of it. We'll keep you confidential. We won't disclose anything." Well, often that's legally not possible. And so you got to be really careful what you promise the person if they're going to help you in the investigation. That's a topic for a whole other seminar, but there's some real important legal nuances around that piece.
Scott Moritz:
You made a very important point that I want to reiterate. When you reach the point where you're doing witness interviews, usually there's a rationale and a thought process that goes into, well, who should we speak to that has line of sight to the issue or issues at hand? There's a pretty good chance that your whistleblower or whistleblowers are in that pool of people that you're going to speak to. So you need to be mindful of the fact that every time you are interviewing a witness, they could actually be one of the people that was sharing information confidentially or anonymously. And I have had several times where the witness that I'm interviewing in the middle of the interview got comfortable with how the interview was going and then just revealed themselves. Not that I'm suggesting that we try to unmask a whistleblower that is seeking to remain confidential, but it does happen sometimes of their own volition. So it's just something to keep in mind when you're kind of planning your interview that you may actually be talking to the whistleblower.
Scott Maberry:
Great point. And you're right, you don't necessarily want to have a particular outcome like that, but your bigger point is I think that you need to be prepared for anything that could happen in a witness interview and sometimes they'll surprise you.
The other thing that comes up in this context with witness interviews is that companies conducting internal investigations sometimes don't understand the necessity of providing the Upjohn warning to the witness. And this is something you really need to be careful about because if the witness ever forms a subjective impression that they have an attorney-client relationship in their personal capacity with the lawyer who's interviewing them, then they're the ones who govern whether there's an attorney-client privilege and they then own the privilege. And that's the opposite of what you want when you're doing an investigation. So in-house counsel have to be really careful when they're interviewing witnesses because if you don't give them the warning that comes from the Upjohn case, which essentially says, "I'm not your lawyer and anything you tell me falls under the cloak of the company's privilege, not yours." That warning is really critical. Otherwise, you may lose access to some of the information that you've gathered because somebody else might be asserting a privilege over.
Moving to the next point, sometimes the allegations that give rise to an investigation are directed at organizational leadership and that can change everything. So in your experience, what steps should be taken beforehand to make sure that the people being implicated can't wield undue influence over the investigation or even prevent it from happening?
Scott Moritz:
Well, it's so important. I've seen a lot of examples where things turn sideways almost immediately because of the seniority of the people against whom the allegations were being levied. And there's different ways to approach it. Often at the outset, let's take for example, this came in through a hotline, there's supposed to be somebody acting as almost like a triage nurse, but of allegations when hotline allegations come through. And if there's an allegation against senior leadership, the default group to receive that information and to make decisions is often like the audit committee of the board if it is a large publicly traded company that has that as an available option. That's an important distinction. And also even just in terms of how you configure your complaint intake process, you should anticipate that at some point someone is going to levy allegations against senior leadership, and you have to have the ability to wall those people off within your investigative protocol.
I think with the answer to every question, we keep making further and further that point that you should have a plan and the plan is going to dictate a lot of what follows in an investigation. And this is a very critically important point, is how do we protect the independence of an investigation when senior leadership could wield the kind of influence that could affect the outcome? And I think the key is you have to anticipate that and plan accordingly. And that default setting is an audit committee of the board or even some sort of special committee of the board that has been created for the purpose of investigating allegations against senior leadership.
So Scott, similar to what we were just talking about, what if the allegations are directed at the legal department because that then kind of makes it an even more complicated set of facts?
Scott Maberry:
Yeah, those cases really tricky, and again, it affects your reporting structure and like the allegation against senior leadership, it also affects your engagement structure. Sometimes if your normal contact, and it very often is for us outside lawyers is the chief legal officer. If that person's department is being implicated in the alleged wrongdoing, you've got to find a way to not do what's normal in most cases and not be reporting straight into the legal department. So again, there's usually a structure where you can report, you can structure the engagement so that you're being engaged by the board or by a committee of the board or by the chair of the board and your reporting structure has to be kind of adjusted accordingly.
It also affects who's conducting the investigation because very often an investigation like this is a very deep collaboration between outside counsel, outside consultants and the legal department. And if you are investigating the legal department, one of the three legs of that stool isn't there. And so it makes your investigation very awkward. You have to be ready for that and really aware of what things that's going to affect. So even as simple a thing as I need to set up interviews with the following four people, usually I'm going through the general counsel's office because usually they're the people who understand what's going on and have the access to the email addresses of the witnesses and have the authority to ask a witness to come in a conference room and meet with me even though they don't know me. So you have to figure out how to work around that if you're investigating wrongdoing or allegations of wrongdoing inside a legal department.
Scott Moritz:
Really good point.
Scott Maberry:
So earlier we discussed the fact that the existence of the investigation and maybe the underlying allegations could become public at some point. People inside the organization are the ones that are most likely to notice if an internal investigation is going on. And so pretending it's not happening or kind of misleading or misdirecting people isn't really advisable. So what is advisable in your experience when the investigation moves to an overt phase? And let's say anybody who's in the building can see an army of outside lawyers and consultants walking in and out of a big conference room on a daily basis, and you start to see anxiety across the organization as a result.
Scott Moritz:
An army of suits is seldom a good sign inside of an organization and it's often overlooked. I think there's this tendency sometimes, particularly a company maybe hasn't had experience like this that often, it's often sort of overlooked that the absence of communication and assurance is going to cause anxiety to go through the roof because the first thing that everybody sort of thinks about is how this going to affect me? Am I going to lose my job? Is the company in trouble? Are we going to go under? There's this infinite list of anxieties that start bubbling to the surface. And absent some sort of messaging from leadership to kind of quell some of those anxieties, the rumor mill is going to rampant, and you're going to see potentially people reacting in a way that first of all is going to make the job harder to do the internal investigation and also cause perhaps misinformation because of some of what's being discussed is stuff that they just heard, but it's not based in any kind of fact.
So earlier we were talking about who's going to talk to the press and what's the script and what should it look like? There also should be an internal script of talking points, that's like, "Hey, listen, we can't tell you everything that's going on. And obviously you're seeing that there's some people in our offices and we are in the middle of ..." If it's okay to acknowledge an internal investigation, say that, but then say what you can say that's assuring of people. "The company's not in trouble. We didn't do anything wrong. Your job isn't at risk." The things that people need to hear for that anxiety level to come down, for the temperature and the room to come down a little bit.
And then talk tracks aren't dissimilar to what you say publicly. It's like, "Hey, we will share what we can share as soon as it's permissible and appropriate to share it with you. But just rest assured, we are looking out for the company and looking out for the best interest, but we have to do what's right." And I think those types of things go a long way. It's not going to make the anxiety go away, but it's going to maybe temper it a little bit.
Scott Maberry:
And that's really the point is that you've got to be ready to do it. I don't know what the script is yet because I haven't seen what the investigation is about yet, but you got to be ready to do it. And as your company's outside lawyer, I'm telling you, I think you want Moritz and Maberry to review that script before you deliver it and make sure that it's not going to compromise anything in the investigation. So that's all the time we have today. We hope you've enjoyed this special edition of Fraud Eats Strategy and Nota Bene. And this has been the two Scots, Scott Moritz of White Collar Forensic, and Scott Maberry of Sheppard Mullin.
Scott Moritz:
Thank you for listening.
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