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Graves-Wiley Direct Sales Compliance Management

Formerly DSCM - Direct Sales Compliance Management

The cases of FTC v. Sea Silver and FTC v. BurnLounge proved that nothing can shut down your business faster than legal and regulatory challenges. Regulatory compliance for the Direct Sales – or MLM – industry is as important as a compensation plan, a marketing plan, and the products and services you are offering the consuming public.

To think otherwise is to gamble with everything: More than 95% percent of a legitimate direct selling company's regulatory headaches and legal risks will come from the field. As a result, a functional, effective compliance department is an absolute necessity to mitigate those risks.

Can you afford not to have your Compliance Department reviewed?

Frequently the signs of non-Compliance are there but difficult to read until it is too late. Graves-Wiley provides licensed and trained investigators anywhere in the U.S. for undercover, in-person audits of training, presentations and overviews. For those complex or extremely sensitive issues needing expert attention, we will complete the investigation expeditiously, discreetly, and professionally.

Note: We do not take the place of your in-house or outside legal counsel. We are not attorneys! We strongly suggest collaborating with yours to coordinate any compliance policy changes you direct.

Why Use Our Compliance Management Services?

Graves-Wiley Direct Sales Compliance Management is the only licensed Private Investigative firm with international resources and a comprehensive understanding of direct sales legal challenges. Working with client's counsel, we build effective world-class compliance departments and deploy comprehensive policies and procedures, including proactive monitoring and enforcement in the field.

Companies must readily adapt to rapidly changing and sometimes obtuse statutes, regulations, and precedents put forth in Federal Trade Commission Guidelines, states’ Attorneys General Consumer Affairs Offices and, of course, the courts. We work closely with many of the best attorneys in this arena. We complement their services with practical application of regulations, bringing our understanding of what a compliance department does and/or building one that is operationally effective.

How We Help Established Companies

There are a number of services we offer to existing companies, beginning with the most critical—a Compliance Audit, wherein we review:

  • Existing techniques and processes.

  • Internal and external communications.

  • How complaints are handled – from start to finish – and the reports generated.

  • How cases are prioritized.

  • Existing policies and procedures as they pertain to Compliance.

  • Existing disciplinary actions; are they used, abused or ignored?

  • Prescribed procedures for case management.

  • Is Compliance used as a weapon or a teaching tool?

  • Reporting responsibility for Compliance.


As beneficial as well-thought-out internal processes and good policies and procedures can be, the continued operation of a company remains at risk if they don’t know how the field is conveying the intended message. To address this, we send fully licensed and trained undercover investigators, acting as potential customers, anywhere in the country to watch, record, and review your independent representatives' behavior in the field. Are they making illegal income claims? Are they making illegal product claims or unsubstantiated medical claims? This service is offered as a periodic, ongoing program.

These reports provide invaluable intelligence regarding what is actually occurring outside of the company’s purview. With this information, any company can determine if a particular upline group might require extra sales training or, if serious enough, disciplinary action for selected leaders. At the same time, your company will be collecting factual, exculpatory evidence for any future claims of non-compliance.

For Start-Up and Young Direct Sales Companies

Graves-Wiley Direct Sales Compliance Management offers experienced contractual, third-party distributor compliance management and oversight. Too often, compliance is the final component added after a new company has been in operation for several years. We help smart companies by overseeing and training their staff in developing and running an efficient department that promotes the desired outcome: profitable continuation of the company and success of its field representatives.

While a new company can’t necessarily afford a fully staffed Compliance Department but needs some assistance, we fill that void. Our clients tell us they see many benefits of this service, including reduced payroll; managed growth; complete training, including letter templates, forms, and processes; and potentially reduced liability for the client company.

Internet Monitoring

The FTC’s guidelines state: “The advertiser (your company) is subject to liability for misleading or unsubstantiated representations made through the blogger’s endorsement.” While the FTC standard does not require perfection, it does demand consistent diligence.

We offer monthly website, blog, and social network screening to clients in order to audit all messages being broadcast to the public.

  • Can your company demonstrate good faith compliance in monitoring and correcting your field representatives’ blogs, testimonials, marketing comments?

  • Are your field representatives following existing company guidelines pertaining to income and/or product claims?

  • Do your field representatives have unauthorized, private websites advertising your opportunity or product?

  • Are there disgruntled ex-employees or failed field representatives denigrating the company with rumors, falsehoods or slander?

  • Are unscrupulous “Prospect List” Internet sales people using your Trademarks and meta-tags to drive traffic to their site?


Any shortcomings in the above can contribute to significant liability issues for your company – and all of them draw unnecessary attention from regulators. Along with appointed counsel of several client companies, we have responded to complaints and inquiries from States' Attorneys General on consumer issues and met face-to-face with them or their investigators when appropriate.

You can entrust your investigative and protective needs to us. We get it right, every time.

For more information about how we can help you, contact us today at 1.800.683.2173.

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