Global Law Firm

PLT was instructed to assist a client whose office had been raided by the European Commission (EC).

To help the instructed law firm review the actions by the regulator and to assist with the document review exercise by quickly capturing and processing the relevant documents for review so a leniency application could be considered.

Supervision of the regulator’s capture process; identification of additional custodians; a multi-layered review that included numerous complex searches; a second phase that involved several simultaneous internal investigations across multiple jurisdictions.

Overview Phase One
The day after the raid, the team arrived on-site to repeat the regulator’s capture process so it could be determined exactly what they had had access to. On arrival, they discovered that the EC was still in situ, so PLT was instructed to supervise the Commission and ensure they stuck to their order and brief.

After the EC completed its raid our experts widened and deepened the parameters of the capture process set by the EC by speaking to the lawyers and staff on-site and identifying additional custodians who might have relevant information. Thanks to this proactive approach, data was collected from approximately 25 custodians in a single day by accessing their computers, network and email data. The data then had to be processed and reviewed and made available to the lawyers for review. Time was of the essence due to the potential applications for leniency so the team worked through the weekend and, by the Monday morning, over one million documents had been made available to the lawyers for search and review.

The review incorporated a number of themes, each comprising complex searches. As a result, the workflow was mapped around that plan so the lawyers could assign reviewers to each part. An efficient and effective review was further ensured by segregating the documents and setting up the coding for each theme.

Overview Phase Two
Following an agreement with the regulator, a second phase came when the company under investigation organised simultaneous internal raids at nine sites across seven countries in Europe and the Middle East. In each instance, PLT was on-site to collect relevant data from laptops and desktops, servers and mobile/smart phones due to concerns over the behaviour of certain employees in each of the different jurisdictions. It was discovered that some of the key custodians had used chat messaging to communicate rather than email. As a result, hundreds of thousands of online chat messages had to be pulled apart so they could be interpreted by the processing and review platforms as mail type data rather than a bespoke chat format. This allowed the lawyers to analyse and consider the complete corpus of communications as opposed to just one medium.

All relevant data was successfully processed and made available for review to the lawyers allowing them to make an early application for leniency.