A video call, three time zones apart
Compliance counsel is interviewing a regional sales manager based in another country. An internal audit flagged payments to a local "business development consultant" whose invoices describe services vaguely and whose fees rose sharply around the time the company won a large government contract.
The sales manager joins the call from a conference room. His English is good but not his first language. An interpreter is available if needed. He's been told only that this is an internal review.
Counsel has the invoices, the contract with the consultant and the procurement timeline. She also has, at the back of her mind, a set of suspicions she must not let shape the interview.
"Can you tell me about your relationship with the consultant?"
"He's very well connected. He helped us understand the process."
That answer could mean many things. The rest of the interview is about finding out which.
A high-stakes, cross-border account
Anti-corruption laws in many countries — including laws with extraterritorial reach — prohibit improper payments to public officials, and many companies conduct internal investigations when concerns arise. An anti-corruption investigation interview is where much of the factual picture is built.
Four features make it difficult.
Cultural and language differences. Norms of relationship-building, directness and hierarchy vary. Words like "connected," "facilitation" and "gift" may carry different meanings.
Multiple legal systems apply. Data protection, employment law, local rules on interviews and cross-border transfer of information may all bear on how the interview is conducted and what can be done with its contents.
The interviewee may have divergent interests. A sales manager whose conduct is being examined may face employment consequences or personal legal exposure. That's why the company's counsel gives a clear warning about whom she represents — covered earlier in this series.
And suspicion is corrosive. An interviewer who conveys suspicion gets defensive, minimal answers. One who conveys a genuine desire to understand gets context.
Before the call
Deliver the role warning clearly. Counsel represents the company, not the employee; the conversation is privileged but the privilege belongs to the company; the employee should keep it confidential. Check understanding — especially across language differences.
Use an interpreter where needed. Offer one rather than waiting for the interviewee to ask. Brief the interpreter on terminology and on interpreting, not summarizing.
Confirm local requirements with counsel. Whether local law affects representation, recording, data handling or the interview's format should be settled before the interview, not discovered during it.
Prepare the documents. Invoices, contracts, payment records, emails and timelines — organized so they can be walked through in sequence.
Build the account
Start with the business context. "Tell me how the government contract came about. Who were the key people, and what were the stages?" A broad narrative gives the interviewee room to explain — and the interviewer context for everything that follows.
Then walk through documents chronologically. "This is the consultant's first invoice, from March. Can you tell me what services it relates to?" Documents anchor the account in facts and reduce reliance on memory.
Ask open questions, then specific ones. "What did the consultant do for the company?" Then: "Who did he meet with? Were any of those people government employees? How were his fees agreed? Who approved them?"
Clarify terms without assuming. "When you say 'well connected,' what do you mean? Connected to whom?" Cultural and linguistic ambiguity is common; clarification should sound like curiosity, not challenge.
Note consistency — without confronting prematurely. If an answer doesn't match a document, ask about it neutrally: "I want to understand this. The invoice says X, and I think you mentioned Y. Can you help me reconcile them?"
Don't signal suspicion or conclusions. No "That sounds like a bribe." No raised eyebrows. The interviewer's view has no place in the interview.
Ask who else knows. Colleagues, approvers, finance contacts, the consultant himself — the investigation will depend on further sources.
After the call
Document carefully. What was said, what documents were shown, the interviewee's explanations and any points of uncertainty.
Consider follow-up. Many cross-border interviews require a second session after documents or other interviews are reviewed.
And escalate according to the investigation plan. Decisions about further steps, disclosure or remediation belong to the investigation team and its legal advisers.
Four ways it goes wrong
The suspicious interviewer, whose tone makes the interviewee defensive and minimal.
The leading questioner, who asks the interviewee to confirm a theory rather than describe events.
The culture-blind interviewer, who treats ambiguous terms as admissions or evasions without clarifying them.
The procedure-skipper, who conducts the interview without settling interpreter, warning and local-law questions first.
Why this isn't trained
Compliance training focuses on rules. What's prohibited is taught thoroughly; how to interview someone about it is not.
Cross-border interviews are rare for most practitioners. They happen infrequently and with high stakes — the worst combination for learning on the job.
Language and culture are underestimated. Interviewers often assume a shared understanding of terms that isn't there.
And practice interviewees share the interviewer's culture. Colleagues playing a regional manager rarely reproduce the linguistic and cultural nuance of a real cross-border interview.
What anti-corruption interview simulation can rehearse
A ten-minute simulation can put counsel opposite a regional manager whose explanations are plausible, culturally inflected and ambiguous — so counsel practices the warning across a language barrier, document-based questioning, neutral clarification and non-suspicious tone. The AI agent in Foretell AI plays the interviewee consistently; the investigation plan, legal analysis, local-law requirements and escalation decisions stay with the investigation team.
Four versions to build:
- The relationship explainer, who describes the consultant’s value in terms of connections.
- The document-inconsistent account, where the explanation doesn’t match an invoice.
- The language-barrier interview, where key terms need careful clarification.
- The defensive manager, who becomes guarded when he senses suspicion — testing whether the interviewer can restore a neutral tone.
Design caution — high tier. Anti-corruption laws, internal investigation practice, privilege, data protection, employment law and local interview requirements vary significantly across jurisdictions. Nothing here describes risk indicators, detection techniques or legal standards, and scenario content should not. Modules must follow the investigation team's legal guidance and should score neutral, document-based questioning — not conclusions about wrongdoing. Nothing here is legal advice.
Designing the module
Ten minutes, scored against an investigation-interview rubric.
Pass one — preparation. Was the role warning delivered clearly and understood? Was interpretation addressed?
Pass two — the account. Did counsel begin with open business context, walk through documents chronologically and clarify ambiguous terms?
Pass three — neutrality. Did counsel avoid signaling suspicion or leading? Were inconsistencies explored neutrally?
Rubric on observable behavior: Was the warning delivered and understanding checked? Was an interpreter offered where needed? Was an open narrative invited first? Were documents used chronologically? Were ambiguous terms clarified? Were leading questions asked? Was suspicion signaled? Were inconsistencies explored neutrally? Were further sources identified?
Clarification of ambiguous terms is the measure. In a cross-border interview, it's the difference between an accurate account and a misunderstanding recorded as fact.
For law firms, corporate legal and compliance teams
Anti-corruption investigations carry serious consequences. The quality of interviews shapes every decision that follows.
Cross-border interviews are hard to practice. Simulation gives investigators repeated experience with language, cultural and procedural complexity.
Neutrality produces better evidence. Interviewees who don't feel accused provide more context and more leads.
And it supports defensible investigations. Careful, documented interviews withstand scrutiny from regulators, auditors and courts.
For law schools, it's a practical introduction to cross-border compliance practice.
Frequently asked questions
How should compliance counsel interview an employee about suspected corruption? Deliver a clear warning about counsel's role, address language needs, start with open questions about business context, walk through documents chronologically, clarify ambiguous terms and avoid signaling suspicion.
Why do anti-corruption investigation interviews need interpreters? Because language and cultural differences can create misunderstandings about key terms. Offering an interpreter proactively helps ensure accurate accounts.
What legal issues affect cross-border investigation interviews? Potentially data protection, employment law, local interview and representation rules, privilege and the transfer of information across borders. They should be addressed with counsel before the interview.
Should investigators confront employees with suspicions? Not in a way that signals conclusions. Inconsistencies should be explored neutrally, with the aim of understanding the account rather than proving a theory.
The short version
"He's very well connected." That could mean a great deal or very little.
Give the warning clearly and make sure it's understood — in his language if needed. Settle local requirements before the call. Start with the business story. Walk through every document in order. Ask what "connected" means. Explore inconsistencies neutrally. Keep suspicion out of your voice.
The interview's job isn't to find corruption. It's to find out what happened — accurately enough that others can decide.
Foretell AI lets law firms and compliance teams build investigation simulations — including cross-border anti-corruption interviews, interpreter-supported warnings and document-based questioning like the one above — with configurable AI interviewees, recordings and rubric-based evaluation. If your investigators first conduct a cross-border interview when it matters most, we're happy to walk through how other teams have structured it.