Driving revenue to enhance enterprise value can be a risky proposition when dealing with foreign governmental agencies or government-owned enterprises. Even companies that have strong codes of conduct forbidding bribery of foreign government officials are by no means immune to the risk of being investigated and subjected to enforcement actions arising from allegations of improper payments to officials. Companies are at risk that their employees and third-party agents may be accused of using gifts, meals or entertainment as a means of influencing or rewarding a favorable governmental action. Even when a company does not itself make an improper payment to an official, it may be accused of making payments to third-party service providers, such as sales agents, while being aware of a high probability that the third party would use the money to make an improper payment. There also is a risk a company will be accused of failing to maintain adequate accounting controls, or of keeping inaccurate books and records, such as those that disguise the true nature of a payment.