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Agencies May Not Rely On Flawed DCAA Audits

Client Alert | less than 1 min read | 02.04.10

In McKissak+Delcan JV II (Jan. 13, 2010), GAO for what may be the first time rejected a DCAA determination that the offeror’s accounting system was inadequate and sustained the protest because the agency had improperly relied on DCAA’s determination in rejecting the offeror’s proposal. Adequacy of business systems is an element of an agency’s responsibility determination when evaluating proposals, and bid protests are likely the only viable forum for contractors to contest findings of system inadequacies.

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Client Alert | 4 min read | 07.22.26

FCPA and National Security Objectives Align: DOJ Announces First Settlement Related to Bribes That Benefited Mexican Cartels

On July 17, 2026, the United States Department of Justice (DOJ) announced that it had entered into a Deferred Prosecution Agreement (DPA) with The Scoular Company (Scoular), an agricultural supply chain company based in Omaha, Nebraska, to resolve allegations that Scoular relied on customs brokers to bribe Mexican government officials to allow Scoular goods to pass customs inspections and be delivered to Mexico from the United States. As part of its resolution, Scoular agreed to pay a $9,769,521 criminal penalty and forfeit an additional $414,351. Scoular also committed to continue cooperating with DOJ on any ongoing or future criminal investigations, implement a compliance and ethics program designed to prevent and detect violations of the Foreign Corrupt Practices Act (FCPA), and periodically report to DOJ on remediation and implementation of compliance measures throughout the term of the DPA....