“It didn’t make sense.” I have now read that line from two very different compliance scandals.
The first one involved the Hewlett-Packard payment of bribes to make a sale of hardware into the Moscow Prosecutor’s Office, and was one of three actions which violated the Foreign Corrupt Practices Act and led to HP agreeing to a fine and penalty of $135 million. This line was uttered to the Wall Street Journal, which broke the story, by a contract accountant on the transaction in question. He could not understand how a $10 million commission payment could be made by HP to one agent, with no contract with HP, who delivered no services to HP, where the money would be wired to an offshore bank in the Jersey Islands, and (finally) when the commission was 25 percent of the total sale.
