Financial matters · National preparation support

Building a Transaction Chronology in a Money Laundering Matter

Organize dates, source references and the sequence of financial events without turning a working chronology into a forensic conclusion.

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

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Define the unit of an entry

A request, approval, transfer instruction and completed settlement can be separate events. Record the event type and the source that supports it. A bank statement may establish a posted transaction while a message explains an instruction. Do not collapse those records into one date without preserving the distinction.

Keep amounts and currencies explicit

Record the original amount, currency, fees and any conversion shown by the source. If a working summary uses converted values, identify the rate, date and preparer. Preserve the original record. Differences between requested and received amounts may require reconciliation rather than an assumption that one source is wrong.

Separate transfers from economic totals

The same funds may appear at several points in a sequence. Preserve transaction identifiers and relationships without independently deciding the legally relevant total. Counsel and qualified financial reviewers evaluate tracing and sentencing amounts. The chronology should expose possible duplication and gaps, not silently resolve them.

Add the person’s role as a separate field

Identify whether you requested, approved, executed, recorded or later learned of the event, with the basis for that account. A transaction’s existence does not establish every participant’s knowledge. SAG can organize these distinctions so counsel can inspect the relationship between the financial source and the personal account.

Continue your preparation

Should every movement be added into one total?

Not without qualified review. Preserve the sequence and identify repeated movements so the applicable calculation can be assessed.

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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