Compliance and Escalation Records

Identify the policy in force

Preserve the version, effective date and relevant training material. Distinguish an adopted policy from a proposal. Counsel evaluates applicable obligations. A current manual should not be used to describe an earlier period without evidence that it applied.

Document actual questions and responses

Keep contemporaneous requests, reviews and escalation communications with dates and participants. Identify what was asked and what response is documented. Do not assume that a missing response means a concern was resolved or ignored.

Separate training from implementation

Attendance, a completed module and demonstrated practice are different records. Preserve each for what it shows. SAG can organize the source index, but does not certify compliance effectiveness or decide how a program affects legal exposure.

Connect the process to the individual

Identify the person’s assigned responsibilities and actual actions. Keep authority changes and known limitations visible. Counsel determines legal significance; the preparation chronology should allow reviewers to inspect the factual basis for claims about oversight or corrective work.

Continue your preparation

• Approval Authority in FCPA Matters
• Documenting Corrective Work in FCPA Matters
• 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.