Consultant and Commission Records

Preserve the compensation terms

Keep agreements, amendments and schedules identifying the payee, period and calculation method. Distinguish a draft proposal from an executed arrangement. Counsel evaluates legal significance. A preparation summary should not silently substitute later terms for those in force at the relevant time.

Identify calculation inputs

Record the sales, milestones or other inputs used by the identified preparer. Preserve the actual calculation and its versions. A percentage, invoice amount and paid amount may differ. Qualified financial reviewers should assess discrepancies rather than a narrative assuming they are immaterial.

Connect evidence of the underlying work

Organize available reports, communications and deliverables with dates and sources. Identify what is missing. Do not create a retrospective document that appears contemporaneous. Counsel determines what review or collection is necessary and who is authorized to conduct it.

Keep personal knowledge attributable

Describe what you prepared, approved or observed and how you know it. Another participant’s explanation should remain attributed to them. SAG can organize the role chronology and factual questions, without certifying performance or the legitimacy of compensation.

Continue your preparation

• Third-Party Records in FCPA Matters
• Books and Records Preparation 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.

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.