Financial matters · National preparation support

Source of Funds Records: Preserve the Evidence Behind Each Description

Prepare a source index for deposits, receipts and transfers that keeps documented facts separate from assumptions about financial origin.

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

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Start with the record behind the label

An account description such as loan, investment or consulting payment is a starting point, not a complete explanation. Identify the agreement, invoice, communication or other contemporaneous source supporting the label. Keep conflicting descriptions visible. Counsel evaluates the legal significance of the actual facts.

Trace the limits of personal knowledge

Describe what you personally knew about the source at the time, how you learned it and what records support that account. Information discovered later belongs in a separate chronology entry. Do not adopt someone else’s explanation as firsthand knowledge or fill missing history with a plausible story.

Record missing links

Identify unavailable statements, incomplete periods and unclear counterparties. A source index can show what remains unresolved without claiming the funds have been traced. Qualified forensic professionals may need to evaluate the relationships. SAG can organize records and questions but does not certify financial origin.

Preserve the original and the working summary

Keep the original file and its location distinguishable from a summary prepared for review. Record who prepared the summary and when. Any correction should remain traceable. The objective is an inspectable file that helps counsel and specialists assess the evidence without concealing uncertainty.

Continue your preparation

Does an invoice establish that funds were lawful?

An invoice is one source. Preserve it with related records; counsel and qualified reviewers assess what the evidence establishes.

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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