Financial matters · National preparation support
Preparation for Finance Employees in Money Laundering Matters
Document actual duties, approval limits and information available to finance staff without equating routine processing with a legal conclusion.
By Joseph De Gregorio · Federal Sentencing Strategist
Founder and President, Sentencing Advocacy Group · November 6, 2026
Request a Private Case Review · (646) 588-8182
Describe the actual workflow
Identify your team, dates, reporting line and routine responsibilities. Distinguish bookkeeping, payment processing, treasury and approval functions. Preserve relevant policies and role changes. A broad title such as finance manager may not explain who made a particular decision or what information was available.
Separate instructions from decisions
Record which actions you performed, which instructions you received and which decisions belonged to others. Identify the supporting sources. Do not assume a supervisor’s knowledge was your own or that following a workflow resolves every legal question. Counsel evaluates the actual facts and applicable law.
Preserve exceptions and escalation records
If the records show questions, approvals, exceptions or escalations, keep them in context. Do not selectively retain only favorable messages. A later recollection should be labeled as such. The professional chronology should make it possible to distinguish documented contemporaneous concerns from later interpretation.
Prepare the broader personal account
Employment history, family obligations and practical plans may be important as the matter progresses. SAG can organize these materials alongside the factual work chronology. Counsel determines legal responses and statements. The preparation process should not assume that every employee has the same exposure or outcome.
Continue your preparation
Does processing a payment establish the legal result?
No conclusion should be drawn from that fact alone. Counsel must evaluate the actual conduct, knowledge and governing law.
Sources and a defined preparation assignment
Official context: U.S. Code: 18 U.S.C. § 1956. Sources checked November 6, 2026. Counsel evaluates the law and the manual applicable to the individual facts and dates. These preparation steps do not determine criminal liability or a sentencing calculation.
Work directly with Joseph to define deliverables, authorized recipients and review dates. An assignment may include a personal and professional chronology, source index, factual review questions and practical preparation calendar. SAG is not a law firm 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, placement or release date is guaranteed.
For counsel: Discuss Support for Your Client. Begin with the role, stage and deadline. Do not send account credentials or privileged advice through the inquiry form.