It's been more than two years since Bernie Madoff's gigantic Ponzi scheme collapsed, but the blame game is just beginning. And many of the victims are jockeying for position, hoping to recover some money from other parties who might be deemed partly responsible for the fraud.

Should Ernst & Young be held responsible for the bad actions of Lehman Brothers? New York Attorney General Andrew Cuomo, who Tuesday slapped the Big Four audit firm with civil fraud charges, thinks so. But it's not an easy question to answer.

For decades, U.S. companies doing business overseas have had to avoid falling afoul of the Foreign Corrupt Practices Act, which prohibits the bribing of foreign officials. But in the past few years, such corporate misbehavior is receiving more attention and increased enforcement, which is making executives nervous.

When companies use the word "immaterial" to describe errors or irregularities in their previously reported numbers, what they're trying to say is that their mistakes involved such small amounts that they don't really matter. Too often, though, that's not really the case.

If the scandal surrounding former Hewlett-Packard CEO Mark Hurd's resignation has taught us anything, it's this: Dishonesty pays at HP -- if you hold a high enough position, that is. Whether we like it or not, employees look to those above them for cues about appropriate workplace behavior, and that includes fraud.

The Foreign Corrupt Practices Act makes it illegal for companies to pay foreign officials to get or retain business, and the U.S. government has been stepping up FCPA enforcement actions: More than three times as many FCPA cases were brought in 2009 than were filed in 2005.

Executives often have the mentality that the "bad stuff" doesn't happen at their company. Averages apply to others, and corporate theft or embezzlement happens elsewhere. And Sarbanes-Oxley was supposed to protect investors from fraud.

Koss Corp. has sued its auditor, Grant Thornton, for failing to find the alleged $31 million fraud perpetrated by Koss' VP of Finance. It's easy to point fingers, but in this case, it seems clear the blame lies with Koss management.

Today, businesses must send 1099 forms to people they pay $600 or more for services rendered. It's a simple way to make sure workers report their income to the IRS. But starting in 2012, businesses will have to send 1099s to other companies too, for virtually every product or service they purchase.

LifeLock's misleading claims about its ineffective identity-theft protection services attracted a Federal Trade Commission lawsuit, which the company settled for $12 million. Now comes even stronger proof its services are worthless: LifeLock's own CEO has had his identity stolen -- multiple times.