So I may have violated the Foreign Corrupt Practices Act while I was on vacation recently.

Now, for the several readers of these pages who work at the Justice Department, let me state clearly that I’m not sure I violated the FCPA, and this isn’t an episode of self-disclosure. But while on vacation in South America, I had an interesting experience crossing the border into Bolivia that certainly felt like paying a bribe to me. Since FCPA compliance is such a vital part of chief compliance officers’ jobs these days, I wanted to recount the tale here as a from-the-front reminder of what your overseas employees encounter every day.

Our story begins in the town of San Pedro de Atacama in Chile’s gorgeous northern desert. San Pedro borders the high-mountain altiplanos region of southern Bolivia, and tourists willing to brave the bad roads and scant bathrooms can take a four-day trek through the mountains to see stunning Bolivian villages and scenery before returning back to Chile.

Assuming, that is, you can get a visa to enter Bolivia.

This is no easy task for Americans. To reciprocate for high visa fees the United States charges (to curb illegal immigration), Bolivia first imposes an entry fee of $135. And proof of yellow-fever vaccination. And proof of U.S. citizenship, such as a birth certificate. And then maybe a few photographs for the files. And oh, wait, maybe a copy of your bank statement too. Although if you don’t have these items, maybe the border guards can waive the requirements—except, of course, for a cash payment of some kind.

Those were some of the horror stories I heard from fellow American tourists in San Pedro, so I asked my Chilean tour operator about these rumored hassles. “Bah, no problem at all,” he answered. “We go to the border. Our guide talks to the border patrol and they decide a price—$40, maybe $45. You give the money and we get a visa right away.”

That’s when the phrase facilitating payment first entered my mind.

Sure enough, two days later there we were, at the lone shack standing between Chile and the Bolivian mountains. I waited in a mud-walled hut across the way as my guide talked to the border patrol. A few minutes later he returned, saying my girlfriend and I could pay a total of $90 for a four-day visa. We pulled together the cash, entered the border station (see nifty photo at right), and gave the clerk the predetermined $90.

“No noventa dollares; cien,” he said. “Diez mas.” Not 90 dollars; 100. Ten more. He wanted another $10.

That’s when I felt a new camaraderie with all those overseas employees chief compliance officers worry about so much. Was this a bribe? Was it normal? Had something been lost in the translations from English to Spanish and back again? What about the other people in my tour group (two Brits and two French, who received no hassle at all) waiting for me to be waved along—should I raise a fuss and inconvenience them? And really, when I make a respectable salary and Bolivian per capita income is $4,500 per year, what’s the big deal over $10?

All those questions shot through my mind, and were quickly dismissed by my guiding impulse to get this over with. I laid another $10 on the desk, and we received our visas.

Maybe this was all routine and perfectly legal. Maybe it was a bribe paid to a foreign official—and now that I’m using the experience for business gain, maybe I did violate the FCPA after all. But at the very least, I certainly have a better appreciation for why employees do.

Compliance headaches have gone global this week, from Nigeria to China.

First, Royal/Dutch Shell finally blinked and settled a civil lawsuit against the company about to start in New York. Relatives of Ken Saro-Wiwa, a Nigerian civil-rights activist hanged by authorities there in 1995, had sued Shell under the U.S. Alien Tort Claims Act for alleged complicity with the government in Saro-Wiwa’s death. Shell agreed to pay $15.5 million to Saro-Wiwa’s family and the survivors of eight other activists executed along with him.

Second, China has announced rather Orwellian plans to require all personal-computer makers that sell PCs the country to include special Web-blocking software with each unit. Ostensibly this is to block citizens’ access to pornography sites, but practically this system will allow Chinese authorities to “update” the list of blocked sites much like your central IT department sends out security patches to your desktop.

To my thinking, both of these events are near-misses for corporate compliance departments: mildly ominous developments that expand, yet again, the list of worries you need to keep in mind. The Alien Tort Claims Act, for example, has gone from a historical chestnut on the law books (it was passed in 1789 and hardly used for centuries) to something rather like a right to private action under the Foreign Corrupt Practices Act: anyone, living anywhere, can sue any company in U.S. courts for providing assistance to a government that does something the plaintiff claims is dangerous.

I recently conducted a podcast interview on the case with Jonathan Drimmer from the law firm Steptoe & Johnson, and man, this stuff seems hazy. How do you craft a code of conduct to insulate yourself from Alien Tort lawsuits? How do you enforce compliance?

The Chinese ruling could also be a ticking time bomb. You can’t wave off compliance with regulations from the world’s largest consumer market—especially one where various government agencies have very cozy relationships with each other, that Westerners often can’t quite perceive. Compliance with the rule itself should be simple enough; either install the blocking software onto the PC’s hard drive, or include a disk carrying the software with the PC’s packaging. That’s a hassle, but it’s not really hard to do.

But there’s something decidedly un-American about cooperating with another government’s censorship efforts. I could even foresee some crafty dissidents from Tibet or Taiwan suing U.S. companies for their cooperation under the Alien Tort Claims Act. And all for a rule that, I’m sure, clever Chinese hackers will be able to circumvent in less than an hour.

Welcome to the global village, folks.

Foolish me—I’ve always thought the phrase “fraud risk in emerging markets” referred to some two-bit shyster in a foreign land, rushing out from his flimsy storefront operation to seduce a clueless U.S. business partner.

Little did I know that the phrase also includes Satyam, the (supposedly) $2.6 billion IT services business that had been a pillar of India’s modern economy. But somehow I suspect most U.S. compliance executives didn’t know that either.

The details of Satyam’s fraud only started to emerge last week, but already they rival any press release from Enron or WorldCom circa 2002: a fictional cash balance of $1 billion, bogus merger proposals to enrich the company’s founder, a board blissfully unaware of the misdeeds beneath its feet. Satyam’s rogue founder, Ramalinga Raju, even went on the lam for a few days just to increase the intrigue.

The inevitable talk of how the Satyam scandal is India’s “Enron moment” has already begun, of course. All the requisite statements from India’s regulators have been forthcoming: that investigations are underway, that Satyam is a rare exception, that investors should remain confident about Corporate India, and so forth. On a certain level it will be fascinating to watch the fallout from Satyam reverberate through that country, and see whether an economic adolescent like India can really put itself on the right course. After all, the United States is the world leader in corporate governance, we had our scandals here in 2002, and we’re still bickering seven years later about whether we’re back on course.

On a more practical level, however, I suspect most compliance executives in Corporate America are, like me, reading the headlines out of New Delhi and thinking, you’ve got to be kidding me. This was one of those few companies in India that supposedly had been doing things the right way—that is, the Western way. It allegedly had all the checks and balances a U.S. company would want in an overseas business partner. Its financial statements received repeated clean bills of health from a respected outside auditor, PricewaterhouseCoopers. And still its corporate governance rotted away from the inside.

The vast majority of businesses in India aren’t corrupt, but they also have nowhere near the governance structures Satyam supposedly had. When U.S. businesses want to work with those businesses, our ethics and compliance rules require elbow grease and executive heartburn, yes—but at some point, you have to trust that your overseas partners are working honestly. Satyam is an ugly reminder that we should keep that point very, very small.

A sub-plot to this sorry Satyam mess is PwC. Nobody is saying PwC auditors in this country had anything to do with the sloppy oversight, nor have I heard any serious arguments that the missteps of PwC’s India branch will somehow endanger the firm as a whole. But this is the second time in three years that one of PwC’s foreign affiliates has encountered disaster: In 2006, Japanese regulators banned ChuoAoyama PwC from public-company auditing work for certifying false financial statements by Kanebo Ltd., a cosmetics conglomerate that collapsed in 2005 after admitting years of hidden losses.

So not only can esteemed, Western-style businesses in foreign markets still pose serious fraud risks; the auditors there can still be asleep at the switch, too. Just what U.S. companies need in a globally competitive world.