What it is
FCPA & DOJ work focuses on preventing, detecting, and responding to foreign-bribery and books-and-records/internal-controls risks in cross-border business. At Melleh Law, we design and stress-test practical compliance programs, manage third-party risk, lead internal investigations, and guide companies through voluntary self-disclosure, remediation, and engagement with DOJ/SEC when appropriate.

A risk-based, program-first approach
Effective compliance is more than a policy binder. We align risk assessment, internal accounting controls, data and testing, training, and incentives/discipline so that day-to-day operations reflect the program on paper. For international clients, we coordinate across jurisdictions (languages, privacy rules, labor law, and local practices) without compromising U.S. enforcement expectations.

Who we serve

• U.S. issuers and subsidiaries, private companies with global sales, and high-growth cross-border startups

• Private equity/venture funds and their portfolio companies (pre-deal and post-close)

• Distributors, agents, consultants, and JV partners that present elevated third-party risk

What we deliver

• Program build or refresh: ABAC policy suite, procedures, control matrices, KPIs

• Third-party lifecycle: risk tiering, due diligence, approvals, contract clauses (audit/termination), and monitoring

• Training & culture: role-based training, certifications, tone-from-the-top messaging, discipline protocols

• Investigations & remediation: triage, forensics, interviews, root-cause analysis, corrective actions

• Regulatory strategy: voluntary self-disclosure assessments, DOJ/SEC engagement, and monitorship readiness

• Deals: M&A pre-sign diligence, post-close look-back, and Safe-Harbor-aligned integration roadmaps

Typical strategies we may employ

• Controls over payments & books: approval thresholds, supporting documentation, vendor onboarding, and off-book prohibition

• Gifts, hospitality & travel playbooks: pre-approval, thresholds, documentation, and government-touch protocols

• Charitable/political & sponsorship reviews: source-of-funds, conflicts, and benefit tracing

• Sanctions/AML alignment: screening and escalation where risk overlaps

• Hotline & whistleblower readiness: intake, triage, non-retaliation, investigation SLAs

• Data & testing: continuous monitoring of red-flag metrics (e.g., high-risk markets, agents, discounts, cash equivalents)

Cross-border deals & growth
In acquisitions, JVs, and distributor expansions, we balance speed and compliance: right-sized diligence, contractual protections, integration priorities, and early fixes to legacy issues—so growth does not inherit avoidable exposure.

Our process

1. Discovery & risk map — markets, government touchpoints, channels, payment flows, third parties

2. Design — program architecture, control testing plan, reporting lines, and KPI dashboard

3. Implementation — policies, contracts, tools, training rollout, and controls embedded in workflows

4. Operate & monitor — audits, analytics, hotline oversight, and periodic certification

5. Investigate & remediate — fact-finding, root-cause, corrective actions, and disclosure strategy where appropriate

This overview is for informational purposes only and does not constitute legal advice. Outcomes depend on your specific facts and the laws, regulations, and agency policies applicable to your situation.