On April 21, 2025, federal prosecutors moved to dismiss a criminal information, filed against Stericycle, Inc., with prejudice, several months prior to the scheduled expiration of Stericycle’s Deferred Prosecution Agreement (“DPA”) with the Department of Justice. The Illinois-based global waste management company entered into the DPA in April 2022 to resolve allegations that it violated the Foreign Corrupt Practices Act (“FCPA”) by causing bribes to be paid to foreign officials in Brazil, Mexico, and Argentina in order to secure contracts and obtain other business advantages.
On April 20, 2022, Stericycle agreed to pay more than $84 million to resolve parallel bribery investigations conducted by authorities in the United States and Brazil. As part of the settlement, Stericycle admitted that it made hundreds of bribe payments totaling $10.5 million to government officials in Brazil, Mexico, and Argentina between 2011 and 2016—a scheme that enabled the company to earn at least $21.5 million in profits, according to the DOJ. Stericycle entered into a three-year DPA with the DOJ and agreed, among other things, to pay a criminal penalty of $52.5 million, to fully cooperate with any ongoing and future DOJ investigations related to this matter, and to retain an independent compliance monitor. In a related settlement, Stericycle agreed to pay the Securities and Exchange Commission approximately $28.2 million and to retain an independent compliance monitor. The SEC agreed to credit Stericycle up to $4.2 million for any disgorgement paid to Brazilian authorities. The term of both monitorships was two years. Following that, Stericycle was permitted to self-report for the remainder of the DPA and SEC Order.
As noted in the motion to dismiss, the DPA provided that if Stericycle were to meet all of its obligations following the term of the monitorship, the DPA would expire and the DOJ would move for dismissal of the criminal information. The motion to dismiss stated that on or about May 20, 2024, Stericycle’s independent monitor certified that the company’s compliance program was “reasonably designed and implemented to prevent and detect violations of the anti-corruption laws.” In addition, Stericycle’s President certified, on or about April 11, 2025, that the company had met the disclosure obligations in paragraph 6 of the DPA. As of April 27, 2025, the court had not yet ruled on the unopposed motion to dismiss.
Government’s Unopposed Motion to Dismiss Information | DOJ Press Release – April 20, 2022 | Deferred Prosecution Agreement | Information