The document discusses increased government scrutiny and enforcement of the Foreign Corrupt Practices Act (FCPA) by the Department of Justice and Securities and Exchange Commission. It focuses on the need for effective due diligence of third parties like agents, distributors, and joint venture partners to comply with the FCPA. Recent enforcement actions against life sciences companies involved alleged bribes through third parties. Effective compliance programs must thoroughly vet third parties and have appropriate expense controls. Due diligence for mergers and acquisitions must also evaluate FCPA risks from a target company's past activities and relationships with third parties.