International business matters · National preparation support
Financial Obligations After an FCPA Matter
Organize actual orders, agreements and financial sources without assuming corporate and individual obligations are identical.
By Joseph De Gregorio · Federal Sentencing Strategist
Founder and President, Sentencing Advocacy Group · November 6, 2026
Request a Private Case Review · (646) 588-8182
Start with the governing document
Keep the actual order, agreement or proposed schedule with attachments. Identify the person or entity named, amount and procedural status. Counsel determines the obligation and its legal effect. A corporate resolution does not by itself establish an individual’s financial position.
Keep different remedies separate
Label fines, forfeiture, disgorgement, restitution or other amounts only as the source documents describe them. Their applicability and interaction require legal review. Do not assume one payment resolves every obligation or that a general description identifies the correct recipient.
Document payments and restrictions
Preserve receipts, dates, recipients and relevant terms. Distinguish a proposed payment from a completed one and a claimed credit from one recognized in a governing record. Qualified counsel and financial professionals assess the treatment.
Prepare a realistic personal financial picture
Organize current income, assets, liabilities and expenses within counsel’s requested scope. Identify uncertainty and restrictions. SAG can help make the source file consistent and reviewable without negotiating obligations or guaranteeing savings.
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.
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