Mandatory Display of Fraud Posters
Client Alert | less than 1 min read | 09.16.11
On September 16, 2011, DoD issued a final rule that requires contractors to prominently display in common work areas -- within business segments performing work on DoD contracts -- fraud hotline posters prepared by the DoD Office of the Inspector General, unless the contract is for the acquisition of a commercial item, will be performed entirely outside the United States, or does not exceed $5 million. This requirement must be flowed down to all subcontracts that similarly qualify.
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Client Alert | 4 min read | 07.22.26
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.
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