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ARTICLE · 08 JUNE 2022

FCPA Update

On April 20, 2022, Illinois-based waste management company Stericycle, Inc. agreed to pay more than $80 million to resolve parallel civil and criminal charges brought by U.S. and Brazilian...

GlobalCorporate/Commercial Law

How Offering Cookies and Chocolates Can Expand Your Business: Stericycle Settles Parallel U.S. and Brazilian Bribery Investigations

On April 20, 2022, Illinois-based waste management company Stericycle, Inc. agreed to pay more than $80 million to resolve parallel civil and criminal charges brought by U.S. and Brazilian authorities related to alleged bribery of foreign officials in Argentina, Brazil, and Mexico.1 According to the settlements, Stericycle made hundreds of bribe payments totaling approximately $10.5 million over a four-year period to foreign officials, profiting by at least $21.5 million. In addition to fines, the company agreed to a two-year compliance monitor, reflecting the government's updated policy of imposing monitorships when the government views a compliance program as not fully implemented or tested prior to settlement.2

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