At Spodek Law Group, we represent clients facing federal investigations across New York. What we see over and over is people who think cooperating will help them. They believe honesty will exonerate them. They think explaining the situation will make this go away faster. Those people usually end up indicted. Not for the crime the FBI was investigating. For lying about it.

The difference between an FBI investigation and an arrest isn't a legal distinction—it's a timing issue. The investigation is when they build the case. The arrest is when they announce they're done building it. Understanding this changes everything about how you should respond when federal agents make contact.

The public thinks FBI investigations are neutral fact-finding missions. Practitioners know they're prosecution tools operating before formal charges exist. The investigation phase is where most federal cases are won or lost, and you have almost no legal protections during it. No discovery rights. No right to confront witnesses. No jury. Just you, federal agents who are allowed to lie, and FD-302 forms that become the official record of what you allegedly said.

The Investigation Started Before You Knew It Existed

Here's what actually happens. The FBI doesn't wake up one morning and decide to investigate you. By the time you receive that first phone call, that first knock on your door, that first "we'd like to ask you a few questions," they've already done most of the work. Surveillance. Bank records subpoenaed. Email accounts accessed. Phone records pulled. Witness interviews conducted. You're under investigation for months or years before you ever know you're under investigation.

The timeline is shocking when you understand it. Federal prosecutors don't execute search warrants to see if they have a case. They execute search warrants when they've already built 80-90% of their case and need physical evidence to complete it. The typical timeline from search warrant to indictment is 30-90 days. Not because they're investigating during those 30-90 days. Because they're finishing paperwork. The investigation already happened.

And if they seize your computers or phones? Add 6-12 months for forensic analysis. But here's the thing nobody tells you—that 6-12 month wait isn't because your case is particularly complex or they're doing detailed work on your specific situation. It's because FBI forensic labs are overwhelmed. They have massive backlogs. Your devices are sitting in a queue. Digital forensic examination takes 6-12 months not because the analysis is complicated, but because there's a line in front of you.

During those months, you're not sitting idle wondering. You're living your life. Going to work. Spending time with family. Maybe you've convinced yourself nothing will come of it. Meanwhile, agents are interviewing witnesses. Sending grand jury subpoenas for additional records. Working with the assigned Assistant U.S. Attorney to determine what charges are supportable based on everything gathered.

The investigation phase is more important than trial, because most federal cases never make it to trial. 90% of federal criminal cases end in guilty pleas. The decisions you make during the investigation—before you've even been charged—determine whether you'll be one of that 90%. And the single worst decision you can make is talking to federal agents without a lawyer present.

This is the part where people make catastrophic mistakes. They think: "I'll just explain what happened. I'll clear this up. I have nothing to hide." What they don't understand is that the FBI already knows what happened. They're not asking questions to find out. They're asking questions to see if you'll lie. And if you do—even an innocent misstatement, even forgetting a detail, even getting a date wrong—that becomes a separate federal crime under 18 USC 1001.

Martha Stewart didn't go to prison for insider trading. She was acquitted of that. She went to prison for lying to FBI agents about allegations the jury found her innocent of.

Witness, Subject, Target — Categories That Mean Nothing

The FBI uses three classifications for people in federal investigations: witness, subject, and target. A witness is someone who has information about a case. A subject is someone whose conduct is within the scope of the investigation—the government isn't sure whether you're a witness or a target. A target is someone the prosecutor believes committed a crime and has substantial evidence against.

Here's what practitioners know that the public doesn't: these classifications are completely fluid. They can change at any time. And the government has no obligation to tell you when they change.

You might start an interview as a witness. FBI agents contact you. They say they're investigating your colleague. They need your help understanding some transactions. You're being cooperative. You're answering questions. Then, mid-interview, you mention your own involvement in something that sounds problematic. Congratulations—you just became a subject. Or maybe a target. The agents won't tell you. The questions continue. But now they're designed to incriminate you, not your colleague.

DOJ policy says prosecutors should inform subjects and targets of their rights if called to testify before a grand jury. But that's policy, not law. And prosecutors are not required by any law to tell individuals where they fit within the investigation before grand jury testimony. So your classification might have changed from witness to target based on something you said three interviews ago, and you have no idea.

The classification system creates a false sense of security. People think: "Well, I'm just a witness. I'm not in trouble." Then 30 days later, a target letter arrives. Or a grand jury subpoena. Or FBI agents are at the door with an arrest warrant. What happened? Nothing happened. Your classification shifted based on evidence gathered—possibly evidence you provided—and nobody told you.

Even if you're genuinely just a witness, talking without a lawyer is dangerous. Under 18 USC 1001, lying to a federal agent is a crime even if you're not suspected of any other crime. Federal felony. Five years maximum sentence. You're now a defendant in the case you were supposedly helping with.

The only classification that actually matters is this: if the FBI wants to talk to you, get a lawyer before you say anything. Witness, subject, target—these are prosecutorial labels that shift like sand. They mean nothing for your legal strategy. They mean everything for the government's investigation strategy, which is precisely why they won't tell you which one you are.

The Asymmetry You Didn't Know About

The system is designed to work against you, and most people don't realize how extreme the asymmetry is until it's too late. FBI agents are allowed to lie to you. The Supreme Court has made this explicitly clear. They can lie about evidence. They can claim co-conspirators are cooperating when they're not. They can minimize the seriousness of the investigation. They can say "this is just routine" when you're actually the primary target. All legal. All permissible. All happens every single day.

You, on the other hand, cannot lie to them. Not even a little. 18 USC 1001 makes it a federal felony to make false, fictitious, or fraudulent statements in any matter within the jurisdiction of the federal government. That includes simply denying guilt when asked by a federal agent. The statute carries up to five years in federal prison. And if there's any connection to terrorism—domestic or international—the maximum jumps to eight years.

They can lie to you, you cannot lie to them. They can deceive you during interviews, you cannot deceive them. The playing field isn't level. It's designed to extract statements they can prosecute.

And it gets worse. FBI interviews are generally not recorded. Let that sink in for a moment. You're having a conversation that could determine whether you go to federal prison, and there's no recording. Instead, one agent asks questions while another takes notes. Afterward—sometimes hours later, sometimes days later—the agents write up a summary of the interview on a form called an FD-302.

The FD-302 is written in the agents' words, not yours. It reflects what they believe you said, filtered through their recollection, their understanding, and their investigative objectives. The FD-302 becomes the official record of what you said. At trial, if you claim you said something different, it's your word against two trained federal agents who have a written report they prepared.

Prosecutors love FD-302s because they're incredibly difficult to challenge. Defense attorneys hate them for the same reason. The form was created days after the interview, based on notes and memory, written by people who have every incentive to make your statements sound incriminating. But it becomes the official government record. It's admissible in court. And juries tend to believe federal agents over defendants.

Here's an example of how this plays out. You're interviewed for two hours. You talk about dozens of transactions, hundreds of details, multiple people and dates and dollar amounts. Three days later, agents write the FD-302. They include the statements that sound incriminating. They leave out context that makes those statements innocent. They characterize your tone and demeanor in ways that suggest consciousness of guilt. Six months later, at trial, you read the FD-302 for the first time and think: "That's not what I said. That's not what I meant. They left out the part where I explained..." Too late. The record is the record.

The Spodek Law Group has reviewed hundreds of FD-302 forms over the years. What we see consistently is that they emphasize inculpatory statements and minimize exculpatory explanations. They're not neutral documents. They're prosecution tools. And you don't get to review them, correct them, or approve them before they become the official record.

18 USC 1001 carries the same five-year maximum sentence as many underlying federal crimes. Bank fraud. Wire fraud. Mail fraud. This means prosecutors can charge you with lying about a crime even when they can't prove the crime itself. The investigation fails? Doesn't matter. They have your false statements. Martha Stewart. Michael Flynn. The pattern repeats: underlying conduct is disputed or dropped, false statements conviction stands.

The Grand Jury Rubber Stamp

Everyone's heard of grand juries. They're supposed to be a shield protecting citizens from unfounded prosecution. Here's the reality: federal grand juries indict 99.99% of the time. According to data analyzed by the Washington Post, federal prosecutors pursued over 160,000 cases in 2009-2010, and grand juries voted not to return an indictment in exactly 11 cases. Eleven.

99.99%
Grand jury indictment rate

11
Non-indictments out of 160,000

80-90%
Target letters lead to indictment

The shield became a sword. Grand juries were created to protect citizens. But because only prosecutors present evidence, because there's no cross-examination, because your attorney cannot enter the grand jury room, grand juries have become rubber stamps. Prosecutors joke that you can "indict a ham sandwich." The statistics prove they're right.

When you receive a target letter—a formal notice from the U.S. Attorney's office that you're the target of a grand jury investigation—understand what that means. It's not a courtesy. It's a final warning that indictment is coming. About 80-90% of target letter recipients end up indicted. The timeline from target letter to grand jury presentation is usually 30-45 days.

The target letter will often invite you to testify before the grand jury. This is a trap. Testifying without immunity is almost never in your interest. You have no lawyer in the room. You have no idea what evidence they have. And anything you say can be used against you. If you misstate anything—even innocently—that's another 18 USC 1001 charge.

Remember the 99.99% rate. The grand jury has already heard from the prosecutor. Your testimony isn't going to change the outcome. It's only going to give prosecutors more ammunition.

By the time you're indicted, the case is essentially over. 90% of federal criminal cases end in guilty pleas. Only about 0.6% of federal defendants are acquitted at trial. The investigation phase—before indictment—is where your fate is sealed. Most people don't even realize they're in the investigation phase until it's too late.