International business matters · National preparation support
Gifts, Travel and Hospitality Records
Organize requests, approvals, attendees and actual expenses without assuming that a category label resolves the legal question.
By Joseph De Gregorio · Federal Sentencing Strategist
Founder and President, Sentencing Advocacy Group · November 6, 2026
Request a Private Case Review · (646) 588-8182
Separate the proposal from the event
Preserve the request, stated business purpose, approval and itinerary. Record what actually occurred where supporting evidence exists. A planned meeting, canceled trip and completed event are different facts. Counsel evaluates the legal context and significance.
Identify recipients and participants
Keep names, organizations and roles as shown in reliable sources, with dates. Do not infer a person’s legal status from a title alone. Where identity or role is uncertain, identify the question for counsel rather than presenting an unverified conclusion.
Reconcile actual expenses
Organize receipts, reimbursements, invoices and payment records. Distinguish estimated budgets from actual spending and refunds. Preserve the source of any allocation among people or purposes. Financial reviewers may be needed to reconcile complex records.
Document your actual role
Identify whether you arranged, approved, attended, processed or learned about the event later. Preserve instructions and changes. SAG can organize the professional account and source index while counsel decides how the facts relate to the applicable law.
Continue your preparation
- Approval Authority in FCPA Matters
- Communications Records 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.
For counsel: Discuss Support for Your Client. Begin with the role, stage and deadline, not privileged advice or credentials, in the inquiry form.