Nebraska-based agricultural supply chain company, The Scoular Company, recently agreed to pay more than $10 million to resolve a U.S. Department of Justice investigation into an alleged bribery scheme involving Mexican customs officials. The deferred prosecution agreement (“DPA”), which was announced by the DOJ on July 17, 2026, was filed in the U.S. District Court for the Western District of Texas. According to the criminal information and the DOJ’s press release, Scoular conspired to violate the anti-bribery provisions of the Foreign Corrupt Practices Act for allegedly using customs brokers at the U.S.-Mexico border to pay more than $400,000 in bribes to Mexican officials. Federal prosecutors further stated that, unbeknownst to Scoular, a portion of the bribe funds benefited individuals connected to cartel operations.
According to the DOJ’s press release and information, throughout the bribery scheme, which ran from approximately 2013 to 2019, Scoular used multiple third-party customs brokers to move shipments of corn and other products across the U.S.-Mexico border. Such shipments were subject to inspection under Mexican law for dirt, soil, and “other impurities,” and the DOJ press release stated that Scoular authorized the customs brokers to bribe customs officials to allow the shipments through even when inspectors found dirt, soil, and other impurities. The DOJ stated that, at the direction of Scoular employees, the brokers paid Mexican officials approximately $2,000 per train and then invoiced Scoular for reimbursement by falsely reporting the payments as reinspection fees. According to federal prosecutors, the scheme enabled Scoular to avoid more than $6.5 million in fees and costs.
To resolve the investigation, Scoular entered into a three-year DPA with the Justice Department in which Scoular agreed to pay a criminal penalty of $9,769,521 along with $414,351 in forfeiture. The criminal penalty reflects a 25 percent reduction from the bottom of the applicable sentencing guidelines range in recognition of the company’s cooperation and remediation efforts. According to the DOJ, although Scoular did not receive voluntary disclosure credit as it did not timely disclose the misconduct to the DOJ, it did receive credit for cooperating with the investigation, including conducting its own internal inquiry, identifying individuals involved in the misconduct, producing responsive documents, and securing counsel for current employees. In addition, Scoular received credit for timely remediation measures, including “(i) increasing compliance sensitivity across the organization through enhanced business engagement; (ii) implementing the findings of an external compliance program maturity assessment and an anti-corruption risk assessment, including by restructuring its compliance function and incorporating senior leadership oversight across compliance and business activities; (iii) reducing operational risk by eliminating the use of customs brokers associated with reinspection fees in Mexico; (iv) strengthening risk-based review and monitoring procedures, and coordinating those efforts through the use of specific software tools; (v) updating and launching a revised Code of Conduct, along with several key policies and procedures related to its compliance program, including anti-corruption, bribery, conflicts of interest, and third party management; (vi) improving and implementing risk-based screenings and approval requirements for third-party providers; implementing anti-corruption and audit right provisions in third-party contracts; (vii) implementing revised financial controls procedures that relate to high-risk transactions, and (viii) providing general and targeted anti-corruption training to relevant personnel.” Scoular also agreed to continue cooperating with any ongoing or future related criminal investigations and to report its remediation progress to the DOJ throughout the term of the DPA.
In a related case, Carlos Leopoldo Alvelais, pleaded guilty to conspiracy to violate the FCPA on October 23, 2025, for his role as a customs broker who paid bribes on Scoular’s behalf. On July 20, 2026, he was sentenced to 18 months in prison and ordered to pay a $250,000 criminal fine for his role in the scheme.
DOJ Press Release | Deferred Prosecution Agreement | Information| Judgment – Alvelais