Financial matters · National preparation support
Commingled Funds: Preserve Sources and Calculation Assumptions
Organize mixed-source account records for counsel and qualified financial reviewers without attempting an unsupported tracing 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
Keep the full relevant statement period
Identify opening balances, deposits, withdrawals and missing periods. A selected transaction list may omit context necessary for qualified review. Preserve original statements and exports with dates and source information. Counsel should determine the appropriate collection scope rather than relying on a selectively favorable sample.
Label the basis for source descriptions
For each proposed category, identify the supporting agreement, receipt or other record. Keep uncertain amounts separate. A working label is not a legal conclusion about the funds. Do not assume that the entire balance has one origin or that a later deposit explains an earlier transaction.
Leave tracing methods to qualified review
Different financial questions may require different assumptions and methods. Record any method used by an identified preparer and preserve its inputs. SAG does not provide forensic tracing opinions. Counsel and qualified experts determine how the evidence and applicable rules affect a proposed calculation.
Make disagreements reviewable
Keep competing schedules, dates and explanations for changes. A useful preparation product identifies the disputed assumption and the record that could resolve it. It does not choose the lowest number by default. The goal is a transparent source file for professional review, connected to the individual chronology.
Continue your preparation
Can SAG certify which funds were criminally derived?
No. SAG organizes records and factual questions; counsel and qualified financial specialists evaluate tracing and legal treatment.
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.