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2013 Interim Executive Compensation Rule Finalized

Client Alert | less than 1 min read | 06.06.14

On May 30, 2014, the government adopted as final, without change, the interim rule published on June 26, 2013, that expanded the Office of Federal Procurement Policy cap on executive compensation to all contractor personnel working on DoD, NASA, and Coast Guard contracts, pursuant to section 803 of the National Defense Authorization Act for FY12. The final rule rejected comments contesting the retroactive application of the expanded cap and made clear that it applies to compensation costs incurred starting on January 1, 2012, for contract awards on or after December 31, 2011.


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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....