In late June 2004, a plant manager for one of Tyson Foods’ poultry processing plants in Mexico sent a memo to company headquarters in Springdale, Ark.: two women who “most definitely do not work for Tyson Foods in Mexico” each were paid 30,700 pesos, or about $2,700, a month and had been for years. Tyson is one of the world’s largest producers of poultry, pork and beef products, a ubiquitous presence in American supermarkets that has been trying to increase foreign sales. The memo set off an ethics scandal that reached into Tyson’s executive suite and raises questions about who, if anyone, is being held accountable for high-level corporate crime.

The women happened to be the wives of two veterinarians stationed at the plants as part of Mexico’s effort to meet high sanitary and processing standards. The veterinarians certified products as suitable for export, a step required by countries like Japan and increasingly sought after by Mexican consumers as an assurance of quality and safety for locally produced processed meats.

A few days later, senior Tyson executives convened a meeting at headquarters. Someone pointed out the obvious. The purpose of the payments was “to keep the veterinarians from making problems,” according to a subsequent memo — in short, bribes. Participants at this meeting — who included the president of Tyson International, the vice president for operations, and the vice president for internal audit — evidently agreed the payments to the wives had to stop. A company lawyer said he was seeking advice on “possible exposure” from the payments, evidently referring to potential liability for maintaining fraudulent records and bribing foreign officials, which are felonies under the Foreign Corrupt Practices Act.

And then, having identified the serious ethical and legal lapses, and the need to stop the bogus payments, this group of executives “were tasked with investigating how to shift the payroll payments to the veterinarians’ wives directly to the veterinarians,” according to a subsequent statement of facts negotiated by Tyson’s lawyers and the Department of Justice.