McCAHON LAW uses a risk-based approach in establishing and developing corporate compliance programs for U.S. government contractors operating in contingency areas. Much of the risk confronting the company resides within the nature of the contracts and the culture where they are performed. (For additional information regarding the challenges faced by U.S. multi-national organizations operating in contingency areas, See, SCCE Article.) In most of the contingency areas, Middle East & AFRICOM, practices such as bribery of government officials, kickbacks, and human trafficking are standard business practices. These risks must be identified, and mitigation measures taken when developing a robust compliance program.