Scoular DPA: A Customs Broker Enables Health and Safety Violations
September 15, 2026
In the second part of a multi-part series in Anti-Corruption Report on the Scoular Company’s Deferred Prosecution Agreement with the Department of Justice, Partner and Co-Chair of the firm’s White Collar Crimes and Government Investigations practice, Adam Safwat, discussed how evidence DOJ obtained from Scoular’s third-party customs broker played a role in its FCPA violations.
Scoular’s FCPA violations stem from paying bribes to Mexican agricultural inspectors via a third-party customs broker to avoid costly reinspection, and Safwat said that the broker’s eventual cooperation with DOJ likely played a key role in the settlement. He noted that if DOJ can prosecute a third-party agent, “they can put enormous pressure on the agent to flip against the company.” The DOJ resolution underscores the importance of having robust compliance and third-party whistleblower protection frameworks.
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