On July 17, 2026, the US Department of Justice announced a three-year deferred prosecution agreement (DPA) with The Scoular Company, a Nebraska-based agricultural commodities firm, involving alleged bribes paid to Mexican government officials in connection with cross-border trade in agricultural products. According to secondary summaries, the resolution carries penalties and forfeiture totaling more than 10 million dollars, and it fits within DOJ’s post-Blanche Memo enforcement framework focused on foreign bribery tied to organized crime, cartels, and cross-border trafficking risks.
Broader significance. This resolution is notable on several fronts. First, it is one of the higher-profile FCPA resolutions of 2026 and confirms that, notwithstanding the Administration’s earlier pause and recalibration of FCPA enforcement priorities, the DOJ continues to pursue cross-border corruption cases that intersect with US national security, cartel-related enforcement, and border-integrity policy. Second, the fact pattern involves a US corporate parent, alleged payments to foreign officials, and cross-border commercial trade, which is precisely the profile that triggers heightened DOJ scrutiny under current policy. Third, the DPA structure signals continued willingness by DOJ to resolve corporate FCPA matters through negotiated agreements when cooperation and remediation are meaningful, rather than pushing to indictment or trial.
Practical implications. For clients with cross-border operations touching the United States, Brazil, Mexico, or other jurisdictions with active DOJ interest, the takeaways are direct: robust FCPA compliance programs remain essential, third-party due diligence on customs brokers and logistics counterparties is a high-risk area, and voluntary self-disclosure combined with genuine remediation continues to matter in penalty outcomes. Multinationals should also revisit internal accounting controls, books-and-records processes, and training for personnel operating at borders and in customs-adjacent roles.
Source: Morgan Lewis