FCPA Investigation Preparation

Identify the source of the contact

Preserve the notice, subpoena or request with its attachments, date and deadline. Record whether it came from the company, an agency or another participant. Do not infer legal status from a general description. Counsel should assess the communication and direct any response.

Map the relevant business periods

Identify employers, entities, teams, territories and responsibilities with dates. An individual may have changed roles during the period under review. Preserve the records supporting those changes so counsel can distinguish actual work from assumptions based on a current title.

Inventory sources within lawful access

List relevant agreements, approvals, accounting records and communications you lawfully possess. Identify custodians and missing periods. Counsel should direct preservation and collection, including cross-border handling. Do not access former employer systems or another person’s account to fill a gap.

Define a focused preparation product

SAG can organize personal background, the professional timeline and factual questions. Legal strategy, interviews and productions remain with counsel. The initial assignment should specify recipients, review dates and specialist questions without presuming guilt or an eventual sentencing outcome.

Continue your preparation

• Individual Roles in FCPA Matters
• Cross-Border Records in FCPA Matters
• FCPA and Foreign Bribery Sentencing 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.