Employee Preparation in FCPA Matters

Describe the real workflow

Identify the team, period, reporting line and routine tasks. Sales, administration, finance and operations may have different information. Avoid using the company’s overall activity as a substitute for the employee’s own duties and actions.

Separate instructions from decisions

Record what you personally did and which instructions or approvals came from others, with supporting sources. Do not assume another person’s knowledge was your own. Counsel assesses the legal significance of the actual conduct and information.

Preserve changes and exceptions

Keep role changes, questions and unusual instructions in their original context. Identify whether a statement is documented or recalled later. Do not contact other participants to align accounts of events; counsel should direct relevant communications.

Organize personal preparation appropriately

Verified employment, education and practical circumstances may be relevant as the matter develops. SAG can organize that material and the factual chronology alongside counsel. The assignment should fit the actual stage without presuming charges, admissions or sentencing.

Continue your preparation

• Approval Authority in FCPA Matters
• Communications Records in FCPA Matters
• FCPA Investigation 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.

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.