The report accuses the company of paying an illegal surcharge of $160,088 to Iraq in 2001.

"This means that the illegal surcharge of 2 percent which has been charged since last July should be refunded immediately."

Credit Restricted "High demand with fixed prices" created the environment for illegal surcharges, Mr. Stone said.

Oil companies had complained that Iraq was squeezing them for illegal surcharges, and Mr. Hussein's lavish spending on palaces and monuments provided more evidence of his access to unrestricted cash.

Instead, said officials who worked with the oil-for-food program, Mr. Hussein's government fought to keep the price as low as possible to leave a margin for oil traders to pay illegal surcharges.

That arrangement, according to the General Accounting Office, "may have been one important factor in allowing Iraq to levy illegal surcharges and commissions."

At one point, the sanctions committee outmaneuvered Mr. Hussein on the illegal surcharges the Iraqis levied on every barrel of oil.

It accused almost half of the companies operating in Iraq during the time of the Oil-for-Food program to have paid either kickbacks or illegal surcharges to secure Iraqi business.

Charging an illegal surcharge, Mr. Klein said, would expose the letter writer to substantial monetary damages for rent-gouging.

All the details, including the regular 10 percent kickback to the tune of $5 billion in illegal surcharges?