FCPA Enforcement And The “C” Word
The recent Scoular Company FCPA enforcement action was a “garden variety” enforcement action.
A company doing business in a foreign country had a point of contact with a “foreign official” in connection with some regulatory aspect of its business and a bribe was allegedly paid.
FCPA enforcement actions in connection with licenses, permits, inspections, customs, or other regulatory issues are very common including prior enforcement actions involving Mexico.
For instance, in 2023 Lifecore resolved an FCPA enforcement action in connection with wastewater discharge permits in Mexico.
Alvelais Sentenced To 1.5 Years
In 2025, Carlos Leopoldo Alvelais pleaded guilty to a Foreign Corrupt Practices Act offense of some sort in the Western District of Texas. (See here for the prior post).
The facts and circumstances of the enforcement action were unclear as much of the substantive court docket was under seal.
However, last Friday the DOJ announced that “The Scoular Company (Scoular), an agricultural supply chain company based in Omaha, Nebraska, will pay over $10 million to resolve an investigation by the Justice Department into a years-long scheme in which it relied on bribery of Mexican officials to deliver trains of goods across the U.S.-Mexico border.” (See here for the prior post).
According to the DOJ release, Carlos Leopoldo Alvelais was a customs broker who paid bribes on behalf of Scoular.
Scoular Resolves $10.2 Million FCPA Enforcement Action
In 2025, Carlos Leopoldo Alvelais pleaded guilty to a Foreign Corrupt Practices Act offense of some sort in the Western District of Texas. (See here for the prior post).
The facts and circumstances of the enforcement action were unclear as much of the substantive court docket was and remains under seal.
However, last Friday the DOJ announced that “The Scoular Company (Scoular), an agricultural supply chain company based in Omaha, Nebraska, will pay over $10 million to resolve an investigation by the Justice Department into a years-long scheme in which it relied on bribery of Mexican officials to deliver trains of goods across the U.S.-Mexico border.”
According to the DOJ release, Carlos Leopoldo Alvelais was a customs broker who paid bribes on behalf of Scoular.
New Counsel In Hobson Cites Recent Supreme Court Decision And How It “Bears Directly On How This Case Was Litigated”
As discussed here, in February Charles Hunter Hobson (who served in a variety of roles at Corsa Coal from 2013 to 2018) was found guilty by a jury for various Foreign Corrupt Practices Act and related offenses in connection with an Egyptian bribery scheme. As highlighted here, the “foreign official” jury instruction in the Hobson case was flawed and Hobson’s motion for acquittal (filed on April 6th) on a variety of issues remains outstanding.
Recently, Hobson switched counsel and is now represented by R. McConnell Group attorneys Ryan McConnell, Matthew Boyden, and Larry Finder. This same group of attorneys recently represented FCPA defendant Ramon Alexandro Rovirosa Martinez. As highlighted in this recent post, in April, Judge Kenneth Hoyt (S.D. Texas) granted post-trial motions to dismiss and acquittal by Ramon Alexandro Rovirosa Martinez and ordered that he be released from prison.
FCPA Professor Turns 17
In July 2009, FCPA Professor was launched with this simple mission statement.
Seventeen years and approximately 4,900 posts later, FCPA Professor is still here and the mission remains the same. In fact, FCPA Professor is the longest running daily information source about the Foreign Corrupt Practices Act around.
What started out in 2009 as a “blog” has turned into a comprehensive website that has been described as “the Wall Street Journal concerning all things FCPA-related,” and “the most authoritative source for those seeking to understand and apply the FCPA.” Along the way, FCPA Professor has been named a Top Law Blog for in-house counsel by Corporate Counsel, a Top 25 Business Law Blog by LexisNexis, and a top 100 Legal Blog by the American Bar Association.