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FCPA Compliance Report

FCPA Compliance Report: Judicial Discretion, Sentencing Advocacy, and a Proactive Compliance Model: Joseph De Gregorio – Part 2

In this episode, Tom Fox welcomes former Wall Street trader Joseph De Gregorio, who was federally convicted and now applies a “compliance rebuild” methodology to demonstrate genuine remediation under legal scrutiny. This is Part 2 of a two-part podcast series.

In Part 2, we cover how federal judges exercise broad discretion despite sentencing guidelines and often form views before the court based on the pre-sentence report and sentencing memorandum, with probation officers’ impressions shaped by a detailed defendant letter and authentic allocution; judges emphasize post-offense conduct and may discount lawyer advocacy. Joseph then summarizes patterns from 400+ white-collar cases, arguing that structural failures precede cultural and operational failures, and introducing the “access to scrutiny ratio” as the most predictive risk indicator. He lists five warning signals: unscrutinized top performers, known but unmapped monitoring gaps, unmanaged performance pressure, quietly resolved senior incidents, and compensation rewarding results without method (noting DOJ’s September 2024 ECCP update). He outlines a proactive Compliance Rebuild approach using human failure audits, reverse access audits, directional speak-up analysis, and DOJ-aligned prosecution simulations.

Key highlights:

  • Pre-Sentence Reports Matter
  • Patterns Across 400 Cases
  • Five Compliance Warning Signals
  • Prosecution Simulation Stress Test
  • DOJ Evaluation Questions and Red Flags

Resources:

Joseph De Gregorio – Founder, JN Advisor™ Maximum Sentence Reduction – Minimum Time Served

📋 Initial Consultation: https://forms.gle/2fLczk7bbwM7KSaP6

Bloomberg Law Contributor: “How to Get a Judge to Reduce Your Client’s White-Collar Sentence” – Bloomberg Law 

Bloomberg Tax Contributor: Tax Fraud Sentencing Has a Gap Defense Attorneys Are Missing

Featured Expert: American Bar Association

Featured Sentencing Mitigation Expert: Law360

Featured Expert on Us Weekly with 5x Emmy Award Winning Journalist Kristin Thorne for her “Uncovered” Series Click Link For Full Video

https://www.usmagazine.com/crime-news/news/federal-sentencing-strategist-reveals-why-some-real-housewives-stars-commit-fraud/

Tom Fox

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Interested in the intersection of Sherlock Holmes and modern compliance? Check out my latest book, The Game is Afoot in Compliance.

Categories
FCPA Compliance Report

FCPA Compliance Report: From DOJ’s 7 Compliance Pillars to Sentencing Mitigation: Joseph De Gregorio’s Compliance Rebuild Framework – Part 1

In this episode, Tom Fox welcomes former Wall Street trader Joseph De Gregorio, who was federally convicted and now applies a “compliance rebuild” methodology to demonstrate genuine remediation under legal scrutiny. This is Part 1 of a two-part podcast series.

Using the Matthew Bowyer illegal sports betting case, Joseph explains the federal pre-sentence interview and pre-sentence report (PSR) process, emphasizing that the probation officer’s credibility assessment and PSR narrative heavily influence sentencing and downstream treatment across the federal system. He describes submitting a 3,500-word personal narrative before the PSR interview, which was attached in full and cited by the judge as mitigation, resulting in a one-year-and-a-day sentence rather than the government’s four-year request. Joseph maps DOJ’s seven corporate compliance program dimensions to individuals via a personal compliance manual, independent accountability structure, credentialed education, verifiable monitoring, documented transparency, voluntary discipline actions, and a post-sentencing continuous improvement plan centered on victims-first accountability.

Key highlights:

  • Joseph’s Wall Street Past
  • The Boyer Betting Case
  • What is a PSR, and why does it drive sentencing
  • Preparing for the Interview
  • From Corporations to Individuals
  • Seven Pillars Framework

Resources:

Joseph De Gregorio – Founder, JN Advisor™ Maximum Sentence Reduction – Minimum Time Served

📋 Initial Consultation: https://forms.gle/2fLczk7bbwM7KSaP6

Bloomberg Law Contributor: “How to Get a Judge to Reduce Your Client’s White-Collar Sentence” – Bloomberg Law 

Bloomberg Tax Contributor: Tax Fraud Sentencing Has a Gap Defense Attorneys Are Missing

Featured Expert: American Bar Association

Featured Sentencing Mitigation Expert: Law360

Featured Expert on Us Weekly with 5x Emmy Award Winning Journalist Kristin Thorne for her “Uncovered” Series Click Link For Full Video

https://www.usmagazine.com/crime-news/news/federal-sentencing-strategist-reveals-why-some-real-housewives-stars-commit-fraud/

Tom Fox

Instagram

Facebook

YouTube

Twitter

LinkedIn

Interested in the intersection of Sherlock Holmes and modern compliance? Check out my latest book, The Game is Afoot in Compliance.