In this episode of Corruption, Crime and Compliance, Michael Volkov breaks down the Justice Department’s $10.2 million foreign bribery resolution with The Scoular Company, an Omaha-based agricultural supply chain company that used customs brokers to pay more than $400,000 in bribes to Mexican officials over six years so that contaminated grain shipments could cross the U.S.-Mexico border despite failed inspections. Volkov walks through the mechanics of the scheme, a strikingly simple pattern of $2,000 per-train payments disguised on invoices as “reinspection fees,” and explains why DOJ treated the case as an aggravated national security matter after determining that some of the bribe money ultimately reached individuals tied to a border cartel, even though Scoular itself had no knowledge of that connection. The episode also unpacks how DOJ applied its Corporate Enforcement and Voluntary Self-Disclosure Policy to the resolution, distinguishing between the voluntary disclosure credit Scoular did not earn and the cooperation and remediation credit it did, resulting in a three-year deferred prosecution agreement, a 25 percent reduction off the bottom of the sentencing guidelines, and no independent monitor. Volkov closes with practical takeaways for compliance officers on managing customs brokers as high-risk third parties, testing the substance behind recurring payments, and moving quickly on voluntary disclosure decisions once potential misconduct surfaces internally.