Customs brokers have long posed FCPA risk for companies. The DOJ’s July 2026 settlement with the Scoular Company (Scoular) highlights why they deserve fresh scrutiny as the second Donald Trump presidential administration (Trump 2.0) sharpens its focus on trade controls and prosecutors leverage cooperating witnesses. This second article in a multi-part series examining Scoular’s settlement investigates how the company found itself in trouble through its dealings with a shady customs broker and offers compliance lessons on how companies should adapt their third-party risk management systems as a result. Part one highlighted the role that transnational criminal organizations played in the settlement. The final installment will examine how Scoular was able to earn credit under the DOJ’s unified corporate enforcement policy for its cooperation and remediation efforts. See “A Primer on Trade Controls for Compliance Professionals: The Enforcement Landscape” (Aug. 12, 2026).