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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Photo of Thomas Hanusik Thomas Hanusik

Tom Hanusik is a partner in Washington D.C. and a member of Crowell & Moring’s White Collar & Regulatory Enforcement Group, which Law360 named a “White Collar Group of the Year” in 2012 and one of ten “FCPA Powerhouses” in 2013. Tom is…

Tom Hanusik is a partner in Washington D.C. and a member of Crowell & Moring’s White Collar & Regulatory Enforcement Group, which Law360 named a “White Collar Group of the Year” in 2012 and one of ten “FCPA Powerhouses” in 2013. Tom is also chair of Crowell & Moring’s Investigations practice and a member of the firm’s Management Board.

Tom’s practice focuses on white collar defense, SEC Enforcement, FINRA Enforcement and internal investigations. He defends publicly traded and privately held companies, senior executives, board members and politicians during internal and government investigations, criminal and civil trials, regulatory enforcement actions, and appeals. Tom has over twenty years of trial and appellate experience. He also leads teams conducting internal investigations on behalf of companies, boards of directors and board committees, as well as advising corporate clients on remedial measures, compliance programs and training. Tom’s recent engagements include representing institutions and executives in matters involving alleged violations of federal securities laws including financial fraud, insider trading, FCPA and Section 5 violations, AML requirements, federal and state tax offenses, public corruption and violations of U.S. export controls and sanctions regulations.

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Photo of Michael Atkinson Michael Atkinson

Michael K. Atkinson is the former chief watchdog of the U.S. intelligence agencies and served in senior U.S. Department of Justice roles spanning two decades. He has led dozens of high-profile investigations and offers clients a rare combination of experience in criminal defense…

Michael K. Atkinson is the former chief watchdog of the U.S. intelligence agencies and served in senior U.S. Department of Justice roles spanning two decades. He has led dozens of high-profile investigations and offers clients a rare combination of experience in criminal defense and corporate compliance. Michael’s practice focuses on white collar defense, national security, internal and congressional investigations, and parallel civil and regulatory enforcement proceedings. His work also includes high-stakes compliance advice on strategic issues such as cross-border investigations and the use of artificial intelligence/machine learning (AI/ML) programs. He is a partner in the firm’s Washington, D.C. office, working with the White Collar & Regulatory Enforcement and Investigations groups. Michael is also a co-leader of the firm’s National Security Practice and Whistleblower Working Group.

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Photo of Alexander J. Kramer Alexander J. Kramer

Alexander J. Kramer is a partner in the White Collar and Regulatory Enforcement Group, bringing a wealth of experience from his distinguished career at the United States Department of Justice (DOJ). Alex has extensive experience in white collar crime and investigations, including the…

Alexander J. Kramer is a partner in the White Collar and Regulatory Enforcement Group, bringing a wealth of experience from his distinguished career at the United States Department of Justice (DOJ). Alex has extensive experience in white collar crime and investigations, including the Foreign Corrupt Practices Act (FCPA) and anti-corruption issues, health care fraud, significant fraud by government contractors, public companies, financial institutions, and other entities dealing with the DOJ, the U.S. Securities and Exchange Commission (SEC), the Commodity Futures Trading Commission (CFTC), and related parallel enforcement actions.

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Photo of Caroline Brown Caroline Brown

Caroline E. Brown is a partner in Crowell & Moring’s Washington, D.C. office and a member of the firm’s White Collar & Regulatory Enforcement and International Trade groups and the steering committee of the firm’s National Security Practice. She provides strategic advice to…

Caroline E. Brown is a partner in Crowell & Moring’s Washington, D.C. office and a member of the firm’s White Collar & Regulatory Enforcement and International Trade groups and the steering committee of the firm’s National Security Practice. She provides strategic advice to clients on national security matters, including anti-money laundering (AML) and economic sanctions compliance and enforcement challenges, investigations, and cross border transactions, including review by the Committee on Foreign Investment in the United States (CFIUS) and the Committee on Foreign Investment in the U.S. Telecommunications Services Sector (Team Telecom).

Caroline brings over a decade of experience as a national security attorney at the U.S. Departments of Justice and the Treasury. At the U.S. Department of Justice’s National Security Division, she worked on counterespionage, cybersecurity, and counterterrorism matters and investigations, and gained unique insight into issues surrounding data privacy and cybersecurity. In that role, she also sat on both CFIUS and Team Telecom and made recommendations to DOJ senior leadership regarding whether to mitigate, block, or allow transactions under review by those interagency committees. She also negotiated, drafted, and reviewed mitigation agreements, monitored companies’ compliance with those agreements, and coordinated and supervised investigations of breaches of those agreements.

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Photo of Anand Sithian Anand Sithian

For high-stakes internal and government investigations and complex regulatory and compliance matters, companies and individuals look to Anand to provide strategic advice and counseling, particularly on issues relating to the Bank Secrecy Act and Anti-Money Laundering (“BSA/AML”), economic sanctions, and digital assets. Anand

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For high-stakes internal and government investigations and complex regulatory and compliance matters, companies and individuals look to Anand to provide strategic advice and counseling, particularly on issues relating to the Bank Secrecy Act and Anti-Money Laundering (“BSA/AML”), economic sanctions, and digital assets. Anand is resident in the firm’s New York office and a member of the firm’s International Trade, White Collar and Regulatory Enforcement, and Financial Services groups.

A former federal prosecutor, Anand leverages his government experience to guide clients through complex white-collar matters, including grand jury and regulatory investigations, enforcement proceedings, and internal investigations. Anand has deep experience in parallel criminal and civil investigations and proceedings, and often represents clients in defending against civil lawsuits related to government investigations.

Representing some of the world’s largest banks and technology companies, Anand has addressed a wide range of issues, including economic sanctions, BSA/AML; economic sanctions and national security; payments and cryptocurrency; securities laws; and cybersecurity enforcement. In the regulatory space, Anand prides himself on providing commercial and actionable advice, including in the developing areas of digital assets, FinTech, and payments.

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Photo of Jeff Severson Jeff Severson

Jeffrey M. Severson represents individual and corporate clients facing complex, high-stakes criminal and regulatory investigations initiated by the full slate of federal and state regulators. Jeff uses his experience navigating the complex demands of regulatory investigations and criminal prosecutions to fashion effective defense

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Jeffrey M. Severson represents individual and corporate clients facing complex, high-stakes criminal and regulatory investigations initiated by the full slate of federal and state regulators. Jeff uses his experience navigating the complex demands of regulatory investigations and criminal prosecutions to fashion effective defense strategies and collaborate with his clients to guide them to successful outcomes.

Jeff has advised clients in investigations launched by the Department of Justice, Securities and Exchange Commission, Commodity Futures Trading Commission, Financial Industry Regulatory Authority, Federal Reserve Board, and offices of state attorneys general, as well as internal investigations that involve potential criminal or regulatory exposure. In particular, he has experience defending allegations related to the Foreign Corrupt Practices Act; securities fraud; health care fraud; environmental, social, and governance–related disclosures; and criminal antitrust violations. Jeff has advised clients across a wide range of industries, including health care, technology, financial services, and defense.

Jeff also maintains an active pro bono practice and focuses on representing clients in asylum and refugee resettlement proceedings, as well as indigent criminal defendants in the Southern District of New York as part of the Criminal Justice Act panel, in cases ranging from narcotics trafficking to securities fraud. For his service, Jeff was awarded Crowell & Moring’s George Bailey Pro Bono Award in 2017.

While at Fordham Law School, Jeff was the senior articles editor for the Fordham International Law Journal, a Stein Scholar for the Public Interest, and a Crowley Scholar in International Human Rights. Prior to law school, he worked for a prominent international human rights organization.

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Photo of Chris Murphy Chris Murphy

Chris Murphy is an associate in the New York office of Crowell & Moring, and a member of the firm’s Antitrust and Competition and White Collar and Regulatory Enforcement practices. His practice is focused on counseling and representing corporate and individual clients in

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Chris Murphy is an associate in the New York office of Crowell & Moring, and a member of the firm’s Antitrust and Competition and White Collar and Regulatory Enforcement practices. His practice is focused on counseling and representing corporate and individual clients in regulatory enforcement actions, government investigations, white collar criminal defense matters, and internal investigations. Chris counsels large companies in risk-assessment and regulatory compliance as well as individual clients on complex civil litigation issues. Chris represents corporations and executives in criminal and related regulatory and complex civil matters, including internal investigations and parallel proceedings by the U.S. Department of Justice, Securities and Exchange Commission, and State Attorneys Generals.

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