A wholly-owned international subsidiary of California-based Hewlett-Packard Co. (HP) pleaded guilty to four Foreign Corrupt Practices Act (FCPA) counts based on a scheme to bribe Russian officials. ZAO Hewlett-Packard A.O. (HP Russia) was charged with conspiracy to violate the FCPA as well as substantive violations of the anti-bribery, books-and-records, and internal control provisions as part of a scheme to win a large technology contract with the Prosecutor General of the Russian Federation. According to the guilty plea, HP Russia operated a complicated sale-and-buy-back deal through a questionable sales intermediary in order to inflate the prices of its goods and services. The excess funds were then allegedly maintained in off-book accounts in order to make illicit cash payments and to finance travel, cars, jewelry, and other luxury goods for Russian officials.See Plea Agreement,United States v. ZAO Hewlett-Packard A.O., No. CR 14-201 (N.D. Cal. Apr. 9, 2014). Two other wholly-owned HP subsidiaries resolved unrelated FCPA charges involving activity in Mexico and Poland. See Letter from Jeffrey H. Knox, Chief, Fraud Section, Dep’t of Justice, and Melinda Haag, U.S. Attorney, to F. Joseph Warin and John W.F. Chesley, Gibson, Dunn & Crutcher LLP (Apr. 9, 2014). In total, the three HP entities will pay $76.8 million in criminal penalties. And, in a related SEC action, HP has agreed to pay another $31.5 million in disgorgement and prejudgment interest. See Order Instituting Cease-and-Desist Proceedings, In re Hewlett-Packard Co., Exchange Act Release No. 71,916 (Apr. 9, 2014); See Deferred Prosecution Agreement, United States v. Hewlett-Packard Polska,SP.ZO.O, CR 14-202 (N.D. Cal. Apr. 9, 2014).