We've noted before that investigators have really stepped up enforcement of the Foreign Corrupt Practices Act, which bars American companies from bribing foreign officials.

The latest news is that Hewlett-Packard--which has its hands full with Mark Hurd's firing and subsequent fallout--has fallen under investigation for its possible role in an alleged scheme of kickbacks to Russian officials. Investigators in Russia, Germany and the United States have been probing alleged bribes totaling $11 million paid to secure a $44.5 million five-year contract, the AP reports.

The probe surfaced in April when authorities arrested three people in Germany and Switzerland as part of an investigation. They were charged with breach of trust, tax evasion, money laundering and other unsavory acts. Six other individuals, none of whom worked for H-P, may have taken part in a bribery scheme.

It's worth reminding people that you cannot take FCPA lightly. Hiding behind overseas consultants and middle-men--over whom you have reduced control-c-an be a prescription for disaster. The DOJ just issued some guidance on the use of consultants who also have relationships with foreign governments. Do not think these consultants offer a strong layer of deniability. Be warned.

For more:
- here's the article

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