ZAO Hewlett-Packard A.O. (“HP Russia”), a Russian subsidiary of Hewlett-Packard Company (“HP”), pleaded guilty to a four-count criminal information charging it with conspiracy to violate the Foreign Corrupt Practices Act (“FCPA”) and substantive violations of the FCPA’s anti-bribery, internal controls, and books-and-records provisions. See Plea Agreement, United States v. Zao Hewlett-Packard A.O, No. 14-CR-201 (N.D. Cal. Apr. 9, 2014). HP Russia was required to pay a fine of $58,772,250. According to the statement of facts filed with the plea agreement, HP Russia used a buy-back scheme to finance a slush fund that was used to bribe Russian government officials who awarded the company a contract with Russia’s Office of the Prosecutor General valued at more than €35 million. Specifically, HP Russia sold products to a Russian partner, bought the same products back through an intermediary at a markup, and then sold them to the Office of the Prosecutor General at the inflated price. The payments to the intermediary were transferred through various shell companies to government officials. HP Russia also maintained two sets of books to conceal the bribery. Earlier this year, HP’s Polish and Mexican subsidiaries entered into a deferred prosecution agreement and a non-prosecution agreement, respectively, related to FCPA violations. HP itself agreed with the SEC to pay $31,472,250 in disgorgement, prejudgment interest, and civil penalties.