Financial Amounts in FCPA Matters

Name what each figure measures

Record whether an amount refers to a payment, contract revenue, profit, compensation or proposed obligation. Identify the source and date. These measures should not be treated as interchangeable. Counsel evaluates the applicable legal calculation.

Preserve calculation inputs

Keep schedules, supporting records and versions with identified preparers. Document currency conversions and allocation assumptions. Qualified financial reviewers may need to reconcile the record. SAG organizes sources and questions but does not issue valuation or sentencing opinions.

Separate company and individual figures

An enterprise-wide calculation may not explain a person’s own conduct or financial history. Preserve both records without assuming personal compensation controls every legal amount. Counsel determines the significance under the actual facts and governing law.

Plan review before deadlines

Identify missing sources and assign specialist questions early. Work backward from confirmed dates supplied by counsel. A preparation calendar should distinguish a completed financial review from an unresolved issue so the narrative does not overstate certainty.

Continue your preparation

• Books and Records Preparation in FCPA Matters
• Financial Obligations After an FCPA Matter
• PSR Preparation in FCPA Cases

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.