International business matters · National preparation support

Executive Preparation in FCPA Matters

Organize leadership responsibilities, delegation and personal history without allowing a senior title to replace the factual record.

By Joseph De Gregorio · Federal Sentencing Strategist
Founder and President, Sentencing Advocacy Group · November 6, 2026

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Define leadership responsibilities by period

Identify entities, territories, reporting lines and actual duties with source documents. A broad title may cover changing responsibilities. Preserve the distinction between formal governance and day-to-day work so counsel can assess the individual chronology.

Document delegation and information received

Keep instructions, reporting arrangements and relevant oversight records. Delegation alone does not determine legal responsibility. Describe what information reached the person and when, rather than assuming complete knowledge or complete separation from the work.

Verify business explanations

Check significant statements against agreements, communications and financial sources. Identify gaps and conflicts for counsel. A leadership narrative should not substitute general claims about culture or intent for inspectable facts about actual decisions.

Prepare the broader personal account

Organize professional history, family responsibilities and documented corrective steps where appropriate to the stage. SAG can coordinate the agreed preparation products; counsel controls legal positions. Neither executive status nor publication credentials guarantee a favorable outcome.

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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.