International business matters · National preparation support
Documenting Corrective Work in FCPA Matters
Distinguish completed personal work from corporate policies, intentions and unsupported claims of change.
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 actual work
Record what the person completed, when, with whom and what documentation exists. Keep personal actions separate from company announcements. A policy adopted by an organization does not by itself establish an individual’s sustained conduct or understanding.
Preserve independent support
Organize records from appropriate providers, supervisors or other sources where relevant and authorized. Identify the scope of each observation. A certificate shows completion of a stated activity; it should not be described as proof of every claimed personal change.
Connect the account to established facts
Counsel should review how accountability and corrective work fit the procedural stage and factual record. Do not imply admissions that have not been made or claim that later conduct erases earlier events. Preparation should remain accurate and proportionate.
Describe plans as plans
Future commitments should identify practical steps and what remains unconfirmed. Avoid presenting intentions as achievements. SAG can organize completed work, supporting sources and the preparation calendar while counsel decides what is relevant to any submission.
Continue your preparation
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.