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Sarbanes-Oxley Certifications As A Basis For Books And Records Violations


As highlighted in this prior post, the DOJ recently announced criminal charges against Abraham Cigarroa Cervantes (a Mexican citizen described as a former finance director of the Latin America division of Stericycle).

The alleged conduct was in connection with the same bribery schemes at issue in Stericycle’s 2022 FCPA enforcement action as well as the related 2024 FCPA enforcement action against Mauricio Gomez Baez (a Mexican citizen who was the former Senior Vice President of Stericycle’s Latin American).

As stated in the DOJ release announcing the Cigarroa enforcement action:

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DOJ Charges Another Former Stericycle Executive


In mid-2022, Stericycle (an Illinois based medical waste disposal company) resolved a net $59 million parallel DOJ and SEC Foreign Corrupt Practices Act enforcement action (see here and here for prior posts).

In the words of the DOJ: “From in or about and between at least 2011 and 2016, Stericycle, through certain of its employees and agents, knowingly and willfully conspired and agreed with others to corruptly offer and pay approximately $10.5 million in bribes to, and for the benefit of, foreign officials in Brazil, Mexico, and Argentina in order to obtain and retain business and other advantages for and on behalf of Stericycle. Stericycle earned approximately $21.5 million in profits from the corrupt scheme and through its corruptly obtained and retained government contracts.”

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