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Deliver Uncompromised – or Else? DoD Considers Elevating Security in its Procurement Process

Client Alert | 1 min read | 08.14.18

Contractors may soon need to recalibrate their approach to DoD procurements. The Department recently announced that it is reviewing a strategy dubbed “Deliver Uncompromised,” which lays out recommendations for how it can better secure its vast and varied supply chain. Central to the strategy is an increased focus on security in the procurement process. A contractor’s overall security would join cost, performance, and schedule as key evaluation pillars – marking a significant shift in how contractors compete for work. The strategy recognizes, however, that its success would likely require increased incentives for the contracting community to invest in risk mitigation, including liability protections and tax incentives. Although only a proposal for now, the strategy is yet another indicator of the government’s broader emphasis on supply chain security. Just yesterday, the National Defense Authorization Act for Fiscal Year 2019 was signed into law in record time, with several provisions focused on the same issue.  

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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....