This recent post checked in on the Foreign Corrupt Practices Act enforcement action against Abraham Cigarroa Cervantes (pictured – a Mexican citizen described as a former finance director of the Latin America division of Stericycle).
In terms of background, 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.”
In February 2024, the DOJ criminally charged Mauricio Gomez Baez based on the same core conduct. (See here for the prior post). 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.
The information charged conspiracy to violate the FCPA’s anti-bribery provisions and alleged that Gomez Baez and co-conspirators bribed “Mexican, Brazilian, and Argentinian officials to obtain and retain contracts and other business advantages on behalf of and for the benefit of Stericycle.”
Gomez Baez pled guilty in 2024 and was sentenced to seven months in prison, followed by three years supervised release, and ordered to pay a $250,000 fine.
In March 2024, the DOJ also criminally charged Cigarroa in connection with the same bribery schemes. (See here for the prior post). Cigarroa was charged with one count of conspiracy to violate the Foreign Corrupt Practices Act’s (FCPA) anti-bribery provisions and one count of conspiracy to violate the FCPA’s books and records provisions.
According to this article, Cigarroa was arrested in December 2025 in Argentina while hiking with his family in Patagonia and earlier this spring Cigarroa was returned to the U.S. to be arraigned and he plead not guilty. A $1.5 million bond was paid and trial was scheduled for June 1st.
However, on May 21st Cigarroa plead guilty to conspiracy to violate the FCPA’s anti-bribery provisions. The factual proffer statement in connection with the plea agreement states, in pertinent part:
“[Between 2011 and 2016, Cigarroa] and other employees and agents of Stericycle knowingly and willfully conspired to use, and did use, the mails and means of instrumentality of interstate commerce, including U.S.-based e-mail communications, and travel between Mexico and the United States, to corruptly, offer, promise to pay, authorize the payment of, and pay, approximately $3,489,686 in bribes to Mexican government officials, in order to influence those officials in their official capacities and to secure improper advantages to assist Cigarroa, Stericycle, and others, in obtaining and retaining business in Mexico. Stericycle also paid bribes, with Cigarroa’s knowledge, in Brazil and Argentina to obtain and retain business advantages and to direct business to Stericycle. Stericycle earned approximately $21.5 million in profits from the corrupt scheme. Cigarroa knew that this conduct was unlawful.”
According to the factual proffer:
“[I]n exchange for the bribes, they secured improper advantages in order to obtain or retain business from at least fifteen Mexican state-owned entities. These advantages included manipulating the procurement process to obtain government contracts for medical waste collection, obtaining priority release of payments, allowing Stericycle to overbill its government customers, and permitting Stericycle Mexico trucks carrying hazardous waste to avoid repairs and fines. […] Cigarroa authorized the distribution of funds to the Mexican Vendors, which purported to provide services to Stericycle Mexico, in order to generate funds to make bribe payments to officials employed by state-owned and state-controlled hospitals and other government entities. Bribes were typically paid monthly to these officials and were calculated as a percentage of the customer’s invoice value, a percentage of the amount of waste collected, or as a fix amount. Most of the bribe payments were made in cash and were referred to in code, as “IP” payments.”
The factual proffer also states:
“On March 31, 2016, Cigarroa, in his then role as Financial Controller for Stericycle Mexico, signed a Stericycle Business Unit Representation letter that stated, in sum and substance, that he had “no knowledge of actual or suspected fraud, bribery, or corrupt payments affecting the Business Unit” the previous quarter.”
[…]
“Although Cigarroa was primarily based in Mexico, he also gathered information about and reported on bribes other Stericyle executives paid in Brazil and Argentina.”
According to the court docket, sentencing is set for July 10, 2026 in the S.D. of Florida.
