The investigations bench companies staff for the wrong lawyer.

The investigations bench a general counsel staffs sits inside the company. Public 2025–2026 postings for that corporate seat ask for a New York license or Part 522 in-house registration, a decade-plus of investigations or industry enforcement work, and the ability to run remediation with the business. They do not write “former AUSA” as a hard gate. A global pharmaceutical company, posting in May 2026 for a Head of U.S. Litigation & Investigations, asked for 15 or more years of litigation or government-investigation experience in a law firm, government, or in-house legal department, plus significant healthcare or pharmaceutical industry experience including false-claims work — and had the chair report to the North America general counsel and head of legal. Former-prosecutor status was not on the gate list. Industry plus investigations tenure was.

Bank Legal seats in New York use the same three-path gate. Government Investigations & Regulatory Counsel and Senior Counsel for regulatory enforcement, captured in August 2026 postings, asked for ten or more years across in-house, firm, government or regulatory investigations work, and a New York or New Jersey qualification. Government is one acceptable path. It is not the only path. A parallel Global Security chair — Head of Investigation Operations — asked for ten or more years leading intake and investigations operations, with no J.D. gate. A head of legal who staffs that operations role as Investigations Counsel has hired the wrong person.

Name the compliance boundary once and leave it. A New York-metro biopharma Associate Director, Compliance Counsel, reprinted on 5 September 2026, coordinates compliance investigations worldwide at $176,100 to $287,300 and reports into Compliance, not the general counsel. Sibling pages own compliance hiring and chief compliance officer pay. This page owns the Legal investigations bench those functions hand a file to.

On a sensitive file the reporting line can leave Legal altogether. The Association of Corporate Counsel’s Internal Investigations InfoPAK, still the ACC-hosted playbook, puts supervision of a matter that suggests illegal activity with a committee of independent directors — for public companies, often the audit committee — with authority since Sarbanes-Oxley to engage special counsel. The Department’s September 2024 ECCP asks where the compliance function sits and whether it has direct access to the board or the audit committee. A head of legal who cannot say which chair holds the file on day one has not finished the requisition.

Sartori’s quarterly survey since 2019 is the second instrument on the same New York book. In the 2025–2026 waves, 44 of 96 New York in-house respondents who had opened an investigations seat in the prior 18 months said they had declined to interview a monitorship or remediation CV. A chief legal officer at a global bank later told us the lawyer the company had declined — a monitorship alumnus — was the only person on a later shortlist who could answer the Department’s root-cause question without a panel memo. The discarded profile is not a sentiment. It is a hiring habit we can count.

Firm-side directories explain why the habit persists. Chambers USA 2026 labels the New York practice Litigation: White-Collar Crime & Government Investigations and splits it into Elite, Highly Regarded and Specialist Firms; the Specialist column is the individual-defense bench a company shortlist often copies. Legal 500 United States splits the same work into Advice to corporates and Advice to individuals. The shortlist that hunts former prosecutors is the second column. The company is buying the first column as an employee. White collar defense remains a real firm-side practice. It is context for a general counsel, not the spine of this seat.

The public-sector farm that feeds that second column is still large. The Fraud Section counted more than 200 attorneys after absorbing the former Consumer Protection Branch (Year in Review, January 2026). Gibson Dunn, in its 3 February 2026 corporate-resolutions update, recorded that 85 percent of 2025’s 74 negotiated corporate resolutions involved a U.S. Attorney’s Office. Those offices produce excellent panel counsel. They do not automatically produce a head of legal who can hold a 120-day clock. Of 89 New York lawyers in that same interview cohort who had actually sat an investigations or monitorship file, 62 said the company shortlist never asked about remediation ownership.

Write the requisition for the file, not for a former title. We have worked in the New York market for more than ten years, for general counsel, chief legal officers and heads of legal in banks, life sciences and industrials. Over the last three years we closed 24 in-house searches at 93 percent completion, with a 28 percent counter-offer incidence and a median of 16 working days from offer to acceptance, on a typical four-to-seven-month timeline. Of the 11 investigations seats inside that book, nine completed. Three of the 11 drew a stay-put counter-offer. Two did not complete.

The uncomfortable arithmetic is the rewritten brief. Seven of those 11 opened on a former-prosecutor specification. Four of those seven had to be rewritten before a first offer, and two of those four then filled from the remediator pool we had originally been told not to call. We spent the first six to ten weeks of those mandates running a market the client did not need. A page that only reports the 93 percent would be selling the method. The four rewrites are why the rest of the book is believable.

Our New York mandate files record packages, not an investigations-counsel median. We cannot price this seat as a title from our own book, and neither can ACC. A general counsel who wants a number should use the posted pharmaceutical band and the ACC Associate General Counsel median, then decide whether the company is buying a Senior Attorney who can run a privileged review or a head of legal who will sit in the senior-manager definition under Crime and Policing Act section 250 from 29 June 2026. That UK rule attributes every domestic offence of a senior manager to the organization. There is no reasonable-procedures defense on the face of the section. Knowing which in-house titles are senior managers in fact is part of the investigations brief.