Increased regulation, whistleblower incentives, scrutiny by regulators and the Yates Memo all highlight the importance of conducting an effective investigation. No single factor will determine if an investigation should be conducted internally or externally by an independent third party. However, a robust compliance program should have protocols to help assess the need for independence and additional skills and capabilities. Having the right protocols in place will allow an organization to evaluate all the factors in determining the need for external assistance. It will also help ensure that a complete, thorough and timely investigation will be performed in a cost-effective manner that results in minimizing the exposure to the risks associated with the allegations.