SEC Charges Stericycle with Bribery Schemes in Latin America
summary
Stericycle, Inc. agreed to pay over $84 million to settle charges of violating the Foreign Corrupt Practices Act through bribery schemes in Argentina, Brazil, and Mexico from 2012 to 2016.
paragraph
Stericycle, Inc. was charged with violating the Foreign Corrupt Practices Act for orchestrating bribery schemes in Argentina, Brazil, and Mexico between 2012 and 2016. The company agreed to pay over $84 million in total to resolve parallel civil and criminal actions, including $28.2 million to the SEC, which will be reduced to a minimum of $24 million after a credit for payments to Brazilian authorities. Stericycle consented to a cease-and-desist order and must retain an independent corporate monitor for two years, followed by one year of self-reporting.
narrative
Stericycle, Inc. was charged by the SEC with violating the Foreign Corrupt Practices Act for orchestrating bribery schemes in Argentina, Brazil, and Mexico between 2012 and 2016. The company used code names like 'alfa' and sham third-party vendors to conceal cash payments to government officials. Stericycle agreed to pay over $84 million in total to resolve parallel civil and criminal actions, including $28.2 million to the SEC, which will be reduced to a minimum of $24 million after a credit for payments to Brazilian authorities. The SEC found Stericycle failed to maintain adequate internal controls or enforce its FCPA policies until 2016, despite widespread misconduct documented in internal spreadsheets. Stericycle consented to a cease-and-desist order and must retain an independent corporate monitor for two years, followed by one year of self-reporting. The SEC's investigation involved collaboration with the DOJ, FBI, and Brazilian authorities.
Classified fcpa(confidence 100%). No EDGAR filing fingerprint (criminal/DOJ-side scheme). detection rule →
Parties
$28.2 million to settle sec chargesapproximately $24 million minimum to secChristine Lyncheric bustoeric i. bustilloglenn gordonjeffrey cookjessica weissmansec investigationsec miami regional officeSecurities and Exchange Commissionstericycle, inc.
Keywords
secstericyclebribery schemeslatin americaschemesmillionbriberylatinamericaorderstericycle briberyschemes latinbrazil mexicomillion settlegovernment customers
Exhibits & Attached Documents (1)
Extracted insights
Dollar amounts 4
- $84.00M $84 million $10M–$100M
- $28.20M $28.2 million $10M–$100M
- $24.00M $24 million $10M–$100M
- $4.20M $4.2 million $1M–$10M
Entities 12
- agency $28.2 million to settle sec charges
- agency approximately $24 million minimum to sec
- person Christine Lynch
- person eric busto
- person eric i. bustillo
- person glenn gordon
- person jeffrey cook
- person jessica weissman
- agency sec investigation
- agency sec miami regional office
- agency Securities and Exchange Commission
- company stericycle, inc.
Triples 15
- SEC announced charges against Stericycle, Inc.
- Stericycle, Inc. violated Foreign Corrupt Practices Act (FCPA)
- Stericycle, Inc. paid bribes in Argentina, Brazil, and Mexico
- Stericycle, Inc. agreed to pay $84 million to settle charges
- Stericycle, Inc. agreed to pay $28.2 million to settle SEC charges
- Stericycle, Inc. paid bribes from 2012 to 2016
- Stericycle, Inc. failed to implement FCPA policies or procedures prior to 2016
- Stericycle, Inc. agreed to pay approximately $24 million minimum to SEC
- Stericycle, Inc. must retain independent corporate monitor for two years
- Eric I. Bustillo is Director of SEC Miami Regional Office
- Jeffrey Cook conducted SEC investigation
- Christine Lynch conducted SEC investigation
- Eric Busto supervised SEC investigation
- Jessica Weissman supervised SEC investigation
- Glenn Gordon supervised SEC investigation
PDF (from attached: pdf)
Text layers
Extracted body text (2,702c)
The Securities and Exchange Commission today announced charges against Stericycle, Inc. for violations of the Foreign Corrupt Practices Act (FCPA) arising out of bribery schemes that took place in Argentina, Brazil, and Mexico. The company has agreed to pay more than $84 million to settle parallel civil and criminal charges related to these schemes, including nearly $28.2 million to settle the SEC’s charges. The SEC’s order finds that Stericycle, a leading provider of medical waste and other services in 16 countries worldwide, paid millions of dollars in bribes to obtain and maintain business from government customers in Brazil, Mexico, and Argentina from at least 2012 to 2016. According to the SEC’s order, Stericycle staff kept and emailed spreadsheets that identified government customers who received bribes. The bribes were referred to with code names, including “alfa” – short for alfajores, a sweet cookie popular in Argentina. The scheme also included sham third-party vendors who used false invoices to conceal cash payments to government clients. Stericycle also failed to have sufficient internal accounting controls in place, such as a centralized compliance department, to prevent or even detect the misconduct, and failed to implement its FCPA policies or procedures prior to 2016. “Stericycle rapidly expanded in Latin America without any meaningful oversight or compliance measures, as evidenced by widespread bribery schemes lasting for many years in most of its Latin America operations,” said Eric I. Bustillo, Director of the SEC’s Miami Regional Office. “Companies in pursuit of global expansion cannot disregard the need for appropriate controls.” Stericycle consented to the SEC’s cease-and-desist order that it violated the anti-bribery, books and records, and internal accounting controls provisions of the FCPA, and agreed to pay approximately $28.2 million in disgorgement and prejudgment interest. The SEC’s order provides for an offset of up to approximately $4.2 million of any disgorgement paid to Brazilian authorities. Therefore, the company's minimum payment to the SEC would be approximately $24 million. Stericycle must also retain an independent corporate monitor for two years followed by one year of self-reporting. The SEC’s investigation was conducted by Jeffrey Cook and Christine Lynch with assistance from Lina Fernandez and Andrew Schiff, and supervised by Eric Busto, Jessica Weissman, and Glenn Gordon. The SEC appreciates the assistance of the Department of Justice Criminal Division’s Fraud Section, the Federal Bureau of Investigation, and the Controladoria-Geral Da União/Advocacia-Geral da União and the Ministério Público Federal in Brazil.
OCR text (2,702c · html-text · 99% conf)
The Securities and Exchange Commission today announced charges against Stericycle, Inc. for violations of the Foreign Corrupt Practices Act (FCPA) arising out of bribery schemes that took place in Argentina, Brazil, and Mexico. The company has agreed to pay more than $84 million to settle parallel civil and criminal charges related to these schemes, including nearly $28.2 million to settle the SEC’s charges. The SEC’s order finds that Stericycle, a leading provider of medical waste and other services in 16 countries worldwide, paid millions of dollars in bribes to obtain and maintain business from government customers in Brazil, Mexico, and Argentina from at least 2012 to 2016. According to the SEC’s order, Stericycle staff kept and emailed spreadsheets that identified government customers who received bribes. The bribes were referred to with code names, including “alfa” – short for alfajores, a sweet cookie popular in Argentina. The scheme also included sham third-party vendors who used false invoices to conceal cash payments to government clients. Stericycle also failed to have sufficient internal accounting controls in place, such as a centralized compliance department, to prevent or even detect the misconduct, and failed to implement its FCPA policies or procedures prior to 2016. “Stericycle rapidly expanded in Latin America without any meaningful oversight or compliance measures, as evidenced by widespread bribery schemes lasting for many years in most of its Latin America operations,” said Eric I. Bustillo, Director of the SEC’s Miami Regional Office. “Companies in pursuit of global expansion cannot disregard the need for appropriate controls.” Stericycle consented to the SEC’s cease-and-desist order that it violated the anti-bribery, books and records, and internal accounting controls provisions of the FCPA, and agreed to pay approximately $28.2 million in disgorgement and prejudgment interest. The SEC’s order provides for an offset of up to approximately $4.2 million of any disgorgement paid to Brazilian authorities. Therefore, the company's minimum payment to the SEC would be approximately $24 million. Stericycle must also retain an independent corporate monitor for two years followed by one year of self-reporting. The SEC’s investigation was conducted by Jeffrey Cook and Christine Lynch with assistance from Lina Fernandez and Andrew Schiff, and supervised by Eric Busto, Jessica Weissman, and Glenn Gordon. The SEC appreciates the assistance of the Department of Justice Criminal Division’s Fraud Section, the Federal Bureau of Investigation, and the Controladoria-Geral Da União/Advocacia-Geral da União and the Ministério Público Federal in Brazil.