Individual Roles in FCPA Matters

Use a dated responsibility map

Record each entity, position, reporting line and period. Distinguish formal authority from actual tasks. Sales, finance, compliance and leadership may see different information. A useful chronology describes the person’s work rather than treating a job title as a complete account.

Identify actions separately from approvals

For a significant event, record whether the person proposed, reviewed, approved, processed or later learned of it. Identify the source for that statement. Shared workflows may require additional review; do not assign conduct solely from an email copy or system permission.

Separate knowledge at the time from hindsight

Keep contemporaneous information distinct from later discoveries. Attribute statements to their source and identify uncertainty. Counsel evaluates how the chronology relates to the allegations. SAG can organize the factual account without supplying legal conclusions about intent or responsibility.

Connect the professional and personal histories

Verify employment dates, education, family circumstances and practical responsibilities as appropriate to the stage. The broader account should remain consistent with source records and counsel’s review. A polished narrative cannot replace missing evidence or resolve a disputed legal question.

Continue your preparation

• Approval Authority in FCPA Matters
• Communications Records in FCPA Matters
• PSR Preparation in FCPA Cases

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.