Investigations
Disclosure obligations while an investigation is still internal
The hardest question in an investigation arrives before the facts do: what must be said, to whom, while the company still does not know what happened.
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Partner, Chair of Regulatory & Investigations
Internal and multi-agency investigations, sanctions and financial crime controls, and voluntary disclosure decisions.
Miriam Castellanos runs investigations. Most begin as a single unexplained transaction, an anonymous report, or a question from a regulator that the company cannot yet answer, and the first weeks determine almost everything about how the matter ends.
She spent nine years in federal enforcement before joining the firm in 2013, which informs the advice she is best known for: that the decision to disclose voluntarily is a strategic decision with a short window, not a compliance formality, and that it should be made by people who have seen how it is received on the other side.
She chairs the practice and wrote the firm's investigations protocol, the standing procedure governing privilege, preservation, and witness interviews from the first hour of a matter. She teaches it to every incoming associate in the Washington office personally.
Representative Matters
Also in Washington
Contact Miriam Castellanos
Write to miriam.castellanos@marloweandsterling.com or call +1 (202) 555-0171. Please describe the matter in general terms and name the parties involved so we can run a conflicts check before discussing anything substantive.