Approval Authority in FCPA Matters

Map authority by date

Preserve policies, delegations and role changes showing who could approve what during each period. A current policy may not describe an earlier workflow. Keep formal documents separate from firsthand descriptions of daily practice.

Identify actual decisions

Connect a proposed transaction to available approvals and execution records. Permission to act is different from evidence of a particular action. If attribution is uncertain, preserve the issue for qualified review rather than deciding it from a title or account name.

Preserve exceptions and escalation

Keep documented questions, overrides and escalation records in context. Distinguish a contemporaneous concern from a later interpretation. Counsel evaluates significance; the preparation file should not selectively omit records that complicate the account.

Explain the person’s boundaries accurately

Describe actual responsibilities, information received and changes over time. Avoid claiming total oversight or no involvement without checking sources. SAG can organize the account and review agenda alongside counsel, without determining legal responsibility.

Continue your preparation

• Individual Roles in FCPA Matters
• Compliance and Escalation Records
• Executive Preparation in FCPA Matters

Official sources and professional scope

Consult the DOJ and SEC FCPA Resource Guide for legal background and DOJ’s FCPA enforcement guidance with counsel. The resource guide’s second edition dates to 2020 and does not by itself establish current policy. Sources checked November 6, 2026; counsel evaluates current authorities and the individual facts.

SAG provides defined personal and professional preparation: a chronology, source index, factual review questions and practical calendar as agreed. Counsel controls legal advice, responses and submissions. SAG is not a law firm, foreign-law adviser or forensic accounting provider. An engagement does not automatically establish privilege.

Based in New Jersey, SAG serves clients nationwide, with travel arranged for cases. No charging decision, sentence, financial result, placement or release date is guaranteed.

Request a Private Case Review

For counsel: Discuss Support for Your Client. Begin with the role, stage and deadline, not privileged advice or credentials, in the inquiry form.