Parts 1 and 2 of this series covered the terms of The Scoular Company’s deferred prosecution agreement and the mechanics of the bribery scheme itself, a six-year pattern of $2,000 payments per train, dressed up as reinspection fees, paid through customs brokers to keep contaminated agricultural shipments moving across the U.S.-Mexico border. In this final installment, we draw out the practical lessons for compliance officers,...

In Part 1 of this series, we outlined the terms of The Scoular Company’s deferred prosecution agreement and how DOJ applied its Corporate Enforcement and Voluntary Self-Disclosure Policy to the case. In Part 2, we go deeper into the facts themselves, because the mechanics of this scheme, and the specific control gaps that allowed it to run for six years, are exactly the kind of...

The Justice Department’s foreign bribery resolution with The Scoular Company, an Omaha, Nebraska-based agricultural supply chain company, is one of the more unusual FCPA cases in recent memory. It did not arise from a company chasing a government contract or a licensing decision abroad. It arose from routine cross-border logistics, corn and other agricultural shipments moving from the United States into Mexico, and a bribery...

Michael Volkov examines how artificial intelligence is transforming internal investigations — and what the Justice Department now expects from companies navigating this new landscape. Michael breaks down DOJ’s updated Evaluation of Corporate Compliance Programs, which directs prosecutors to scrutinize how companies assess AI risks, whether compliance functions have adequate access to data and analytics resources, and what controls prevent the reckless misuse of new technologies....

Every so often, corporate governance debates that we thought were settled come roaring back. The reporting line for the chief compliance officer is one of them. For years, the trend line pointed in the right direction — more companies elevating the CCO to report directly to the CEO, with independent access to the board. Lately, I am seeing troubling signs of backsliding, with companies quietly...

The root of every strong compliance program is a strong culture. I say this on every episode, and I’m going to keep saying it. Culture is the single most important control that your compliance program builds. It’s at the heart of every compliance program—not the policy binder, not the training module. Culture. Here’s what the research really shows: companies with strong ethical cultures perform better...

The individual prosecutions now flowing out of the TD Bank money laundering scandal are a reminder that institutional control failures are ultimately executed, or ignored, one employee at a time. This week, U.S. District Judge Esther Salas sentenced former TD Bank assistant manager Wilfredo Aquino to 46 months in prison and three years of probation for his role in a money laundering conspiracy that moved...

The SEC’s latest enforcement action against Merrill Lynch is a reminder that a transaction monitoring system is only as good as the calibration behind it. On July 1, 2026, Merrill agreed to pay a $7.5 million civil penalty, accept a censure, and consent to a cease-and-desist order to settle SEC charges that it failed to file numerous Suspicious Activity Reports (SARs) between April 2020 and...

In this episode of Corruption, Crime and Compliance, Michael Volkov talks with Aaron Nicodemus, editor-in-chief of Compliance Week, about the state of the compliance profession and the findings of Compliance Week’s latest “Inside the Mind of the CCO” survey. They discuss a troubling reversal in reporting lines, with more compliance officers now reporting through general counsel rather than directly to CEOs or boards after several...

Some third parties create real legal risks. Other third parties create reputational risk. Not all third parties are the same. One of the most important concepts in modern third-party risk management is distinguishing between acting vendors and incidental vendors. An acting vendor performs services on your behalf. Think customer service providers, recruiters, customs brokers, distributors, and payment processors. When these vendors use AI or engage...