Financial matters · National preparation support

Documenting Individual Roles in a Money Laundering Matter

Explain actual duties, actions and changes in knowledge without substituting an enterprise-wide narrative for the individual record.

By Joseph De Gregorio · Federal Sentencing Strategist
Founder and President, Sentencing Advocacy Group · November 6, 2026

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Use a role timeline rather than a single title

Identify the entity, team, dates and responsibilities relevant to each period. Distinguish formal authority from actual work. A founder, accountant, assistant and outside service provider may have different information and duties. The chronology should describe the person rather than presume that organizational involvement establishes identical conduct.

Identify the source of each important statement

Link significant factual statements to a contemporaneous document, firsthand recollection or another identified source. Keep those categories distinct. If two sources conflict, preserve the disagreement and identify a question for counsel. A polished narrative should not hide weaknesses in the underlying record.

Separate knowledge at the time from later learning

For a consequential event, describe what information was available and when additional information arrived. Avoid retrospective certainty. Counsel assesses how the chronology relates to the allegations and established facts. SAG can help the person organize an accurate account without supplying legal characterizations.

Keep the personal record broader than the transaction file

Professional history, family obligations and documented corrective steps may become relevant as the matter proceeds. Organize them with the same care used for financial sources. The aim is a coherent, verified record that counsel can review, not an effort to replace legal analysis with sympathetic generalities.

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Should every company participant use the same narrative?

No. Each person’s actual responsibilities, actions and knowledge require an accurate individual account.

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.

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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.