We often discuss the impact of the Foreign Corrupt Practices Act (FCPA) on companies in relation to their third parties. Topics can include due diligence of third parties, contracting terms and conditions, and management of these relationships. However, just as all US companies are subject to the FCPA and therefore are required to implement compliance programs which meet the strictures of the FCPA, many non-US companies are required to have compliance programs in place to meet contractual requirements.