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).