Case in point: the latest dust-up over potentially improper gifts of "soft money" by foreign citizens and companies to the Democratic Party.

The company said yesterday that the three transactions it discovered involved potentially improper payments from third parties, presumably involving its complicated barter arrangements.

Nearly half of the $3.4 million Mr. Huang raised during the 1996 election campaign was returned as potentially improper.

Under the rules of the pilot program, which some county officials have called onerous, potentially improper bills are examined.

Ms. Watkins has been praised by members of Congress for raising concerns within Enron and Andersen about potentially improper accounting at the company.

The statements raise the specter of potentially improper activity in the solicitation of stakes in Enron's partnerships, legal experts said.

"It's perplexing," he said, noting that he had worked closely with Islamists in developing the text and the music to make sure that nothing potentially improper or blasphemous was included.

In effect, the panel found, Mr. Chinn was making large, potentially improper loans to Mr. Meese.

One person familiar with the investigation said it originally had focused on potentially improper social ties between some of Mr. Smith's subordinates and executives at companies vying for contracts.

The company later fired Mr. Colburn in connection with his involvement in other potentially improper deals.