International business matters · National preparation support
Books and Records Preparation in FCPA Matters
Organize accounting sources, descriptions and revision history for counsel and qualified financial reviewers.
By Joseph De Gregorio · Federal Sentencing Strategist
Founder and President, Sentencing Advocacy Group · November 6, 2026
Request a Private Case Review · (646) 588-8182
Identify the source system and period
Record which ledger, statement or export is being used, its date and the period it covers. Keep original files distinct from working summaries. A selected report may not include every adjustment or related entry.
Separate descriptions from supporting evidence
A payment label should be linked to the agreement, invoice or other record supporting it. Keep conflicting descriptions visible. Counsel and qualified accountants evaluate what the records establish; SAG does not provide an audit or accounting opinion.
Preserve adjustments and versions
Retain material corrections with dates and identified preparers where available. Do not overwrite an original export to make the record easier to summarize. A version history helps reviewers distinguish contemporary entries from later changes.
Connect accounting tasks to individual work
Identify who prepared, reviewed and approved entries, using the actual workflow and sources. A general department assignment does not establish every person’s action. SAG can organize the chronology and questions for professional review.
Continue your preparation
- Consultant and Commission Records
- Approval Authority in FCPA Matters
- Financial Amounts 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.
For counsel: Discuss Support for Your Client. Begin with the role, stage and deadline, not privileged advice or credentials, in the inquiry form.