International business matters · National preparation support
Third-Party Records in FCPA Matters
Organize intermediary agreements, review records and payment sources so counsel can inspect the actual relationship and individual responsibilities.
By Joseph De Gregorio · Federal Sentencing Strategist
Founder and President, Sentencing Advocacy Group · November 6, 2026
Request a Private Case Review · (646) 588-8182
Identify the third party precisely
Record the legal entity, relevant contacts, relationship dates and agreement versions. A brand name or informal description may conceal changes in the contracting entity. Preserve the underlying documents without assuming that the relationship’s label establishes its purpose or legal treatment.
Preserve review and onboarding records
Keep questionnaires, approvals, background materials and documented exceptions within counsel’s collection instructions. Identify who supplied information and who reviewed it. A completed form should not be described as independent verification unless the source record supports that description.
Connect deliverables and payments
Organize invoices, available work records and payment history separately. Identify gaps between the agreement and the supporting material. Qualified legal and financial professionals assess significance. SAG can organize the sequence without deciding whether services occurred or a payment was lawful.
Describe the individual’s involvement
Record actual selection, review, approval and monitoring responsibilities over time. Preserve instructions and changes in authority. Counsel evaluates the evidence; the preparation summary should make the source and limits of each factual statement clear.
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.
For counsel: Discuss Support for Your Client. Begin with the role, stage and deadline, not privileged advice or credentials, in the inquiry form.