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DoD Proposes Significant Amendments to the DFARS Data Rights Scheme

Client Alert | 1 min read | 06.27.16

On June 16, 2016, DoD issued a proposed rule to amend the DFARS to implement section 815 of the National Defense Authorization Act for FY 2012, which made significant changes to the data rights scheme for DoD contracts. Among other things, the proposed rule permits the release of “segregation and reintegration” technical data and computer software outside of the government (subject to restrictions), even when the item, component, or process to which that data pertains or the computer software was developed exclusively at private expense; expands DoD’s ability to order technical data and computer software post-award; doubles the time period in which DoD may challenge asserted data rights restrictions; and expressly imposes no time limit on DoD’s right to challenge fraudulently asserted restrictions.

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Client Alert | 4 min read | 07.22.26

FCPA and National Security Objectives Align: DOJ Announces First Settlement Related to Bribes That Benefited Mexican Cartels

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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