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: