U.S. anti-corruption enforcers routinely introduce new policies and programs promising benefits to companies that self-report, cooperate and remediate issues, but the value of such incentives becomes clear only when the policies are applied in practice. The July 2026 settlement of the first FCPA case under the DOJ’s Department-wide corporate enforcement policy (Unified CEP), introduced in March 2026, offered the first meaningful test of how the new framework would be applied. This third and final article dissecting that settlement – with the Scoular Company, an agricultural firm based in Omaha, Nebraska – analyzes the ways in which the company was able to earn credit for its cooperation and remediation. The first article looked at the role that transnational criminal organizations and foreign terrorist organizations played in the settlement. The second article reviewed the details of the bribery scheme and what it indicates about third-party risk in the second Donald Trump presidential administration. See our two-part series on the Unified CEP: “One Policy to Rule Them All?” (Apr. 8, 2026), and “The VSD Calculus” (Apr. 22, 2026).