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    Aug. 26, 2026

Scoular DPA: DOJ’s Focus on TCOs in Action

The DOJ’s focus on cartels and transnational criminal organizations (TCOs) may expand FCPA risk in ways companies did not anticipate. Its July 2026 settlement with the Scoular Company (Scoular) offers an early example of how prosecutors are implementing the cartel-focused priorities announced in the DOJ's June 2025 memorandum, which directed prosecutors to prioritize FCPA cases involving cartels and TCOs. This first article in a multi-part series dissecting Scoular’s settlement unpacks the role that TCOs played in the settlement. Future articles will explore the conduct that landed Scoular in trouble and how the company’s cooperation and remediation influenced the terms of the deal. See “2025 in Review: DOJ Perspectives on How the Blanche Memo Restarted FCPA Enforcement” (Jan. 14, 2026).

How Compliance Can Advocate for More Resources As Its Remit Continues to Grow

Compliance is a chronically under-resourced department in most companies, even as its remit continues to balloon. Many compliance teams have become responsible for entirely new areas of risk, such as AI governance, sanctions compliance, trade controls and now the insider trading risk that came with the rise of prediction markets. While compliance professionals’ obligations continue to expand, compliance budgets remain constrained and teams never have enough time to accomplish everything on their to-do lists. The Anti-Corruption Report spoke with Mary Shirley, vice president and CCO of Myriad Genetics, about the state of compliance resourcing, how compliance teams can advocate for more resources with company leadership and the board of directors, and how AI is not the solution to the problem. See “How CCOs Can Make the Case for Compliance in Trump 2.0” (Jun. 3, 2026).

CFTC’s 2026 Cooperation Policy: What’s Changed

The new policy (Policy) announced by the Commodity Futures Trading Commission’s Division of Enforcement in May 2026 is designed to incentivize self-reporting and cooperation and to establish a clear path toward declination. However, more guidance is needed to alleviate doubts as to the ultimate benefits of self-reporting, according to legal experts interviewed by the Anti-Corruption Report. In the absence of further clarity, parties should not automatically rush to self-report when they become aware of violations or assume they can easily secure a declination. This second article in our two-part series compares the Policy to the superseded February 2025 Enforcement Advisory and to other agencies’ cooperation policies, assesses its potential impact and provides practical takeaways. The first article summarized the Policy and its cooperation safe harbors. See “Former SEC and CFTC Officials Unpack the 2026 Enforcement Landscape” (Jul. 29, 2026).

Digging Deeper Into Baker McKenzie’s Global Disputes Forecast

Legal, risk, compliance and tax decision-makers at major corporates are concerned that disputes and investigations are growing more complex and involving more enforcers from various countries, Baker McKenzie research shows. The firm published its annual Global Disputes Forecast in early 2026, and then dug deeper with a follow-on survey, the results of which were published in June and July 2026. Baker McKenzie partner Yindi Gesinde discussed the research with the Anti-Corruption Report, providing further insights on the issues that are top of mind for executives and suggesting five ways to prepare for disputes. See “Unifying Risk Assessments: Breaking Silos to Enhance Efficiency and Manage Risk” (Mar. 26, 2025).

Tips on Keeping Codes of Conduct Relevant and Relatable During the AI Transition

One of the major communication challenges facing compliance professionals is ensuring employees are familiar with a company’s code of conduct and related policies. Drafting codes and policies that are living and integral parts of daily work, and resonate with employees enough to encourage engagement, is difficult, but the rise of generative AI could help. In a panel discussion at the Practising Law Institute’s Compliance & Ethics Essentials conference, Jim Walton, a director of advisory services at LRN, and Monica Lopez Reinmiller, Panasonic North America’s CCO, discussed insights from LRN’s 2025 Code of Conduct Report and suggested ways companies can improve their codes of conduct and policies using old-school compliance know-how, as well as generative AI tools. This article synthesizes their insights. See “The Data Analytics and AI Transition in Compliance” (May 6, 2026).

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