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DOJ Charges Another Former Stericycle Executive

stericle

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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Thoughts On Recent DOJ Speeches

Thoughts

Reading speeches by high-ranking DOJ officials through the lens of a specific law is interesting.

For instance, in recent speeches both Deputy Attorney General Lisa Monaco and Acting Assistant Attorney General Nicole Argentieri talked about the importance of individual accountability.

Monaco stated that the DOJ’s “first priority has been — and will continue to be — individual accountability. Companies can only act through individuals. The rule of law demands that those most culpable for a company’s misconduct are the ones being charged, prosecuted, and convicted.”

Likewise, Argentieri stated “companies act only through people, and so, above all, our number one goal is holding culpable individuals accountable — including corporate executives, no matter how prominent or influential.”

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Deputy Attorney General Lisa Monaco On ….

Monaco

Life follows a certain cycle.

March.

Lots of basketball, the days get longer, and a high-ranking DOJ official speaks at a white-collar crime conference.

So it was as Deputy Attorney General Lisa Monaco delivered this speech at the American Bar Association’s National Institute on White Collar Crime.

Monaco framed her speech as providing “an update on [the DOJ’s] efforts and tell[ing] you what’s top of mind as we confront today’s corporate enforcement landscape.”

She discussed the following topics: individual accountability, recidivism, and incentives (including a new DOJ whistleblower pilot program).

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DOJ Charges Former Stericycle Executive

stericle

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.”

Last week, the DOJ filed criminal charges against Mauricio Gomez Baez based on the same core conduct. As alleged in the information, Gomez Baez (a Mexican citizen and resident of Miami) worked for Stericycle as the Senior Vice President of Stericycle’s Latin American (LATAM) division whose business responsibilities included oversight and management of Stericycle LATAM and certain of Stericycle subsidiaries, including acquisitions, operations, finance, and sales.

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