The U.S. Securities and Exchange Commission (SEC) charged Hewlett-Packard with violating the Foreign Corrupt Practices Act (FCPA) when its subsidiaries in Russia, Poland, and Mexico made improper payments to government officials to obtain or retain public contracts. From approximately 2000 to 2007, HP Russia paid more than $2 million through agents and shell companies to a Russian government official to retain a multi-million dollar contract with the Office of the Prosecutor General of the Russian Federation. From approximately 2006 to 2010, HP Poland provided gifts and cash bribes worth more than $600,000 to a Polish government official to obtain contracts with the national police agency. HP Mexico paid more than $1 million in inflated commissions to a consultant as part of its bid to win a software sale to Mexico’s state-owned petroleum company, Petroleos Mexicanos (Pemex). At least $125,000 of the commissions was funneled to a government official at Pemex. HP consented to the SEC’s order, which found violations of the Securities Exchange Act of 1934. The company agreed to pay $29 million in disgorgement ($2.5 million of which went toward HP Mexico’s resolution of a parallel U.S. government criminal investigation) and $5 million in prejudgment interest.