On March 19, 2024, a federal grand jury in Florida indicted Abraham Cigarroa Cervantes, a former executive of Stericycle Inc., an international waste management company, for his role in an alleged scheme to pay approximately $10.5 million in bribes to officials in Latin America. According to court documents, Cigarroa Cervantes, a citizen of Mexico and former finance director of Stericycle’s Latin America division, participated in a scheme to bribe government officials in Brazil, Mexico and Argentina between 2011 and 2016, in order to retain business and secure contracts to provide waste management services in these jurisdictions. He has been charged with one count of conspiracy to violate the Foreign Corrupt Practices Act and one count of conspiracy to violate the FCPA’s books and records provisions.
According to the Department of Justice, Cigarroa Cervantes conspired with others to make bribe payments, usually in cash. The unlawful payments made in all three countries were allegedly tracked on spreadsheets using code words, and were recorded as legitimate expenses in Stericycle’s books, records and accounts. Federal prosecutors allege that Cigarroa Cervantes also “falsified Sarbanes-Oxley certifications and business unit representation letters” to indicate that the books, records and accounts were accurate.
In a related matter, federal prosecutors in Miami recently unsealed an information charging Mauricio Gomez Baez, the former Senior Vice President of Stericycle’s Latin American division, for his participation in the same alleged bribery scheme. Gomez Baez was charged with one count of conspiracy to violate the FCPA in connection with the payment of approximately $10.5 million in bribes to Mexican, Brazilian, and Argentinian officials between 2011 and 2016.
In 2022, Stericycle agreed to pay more than $84 million to resolve parallel bribery investigations by US and Brazilian authorities. As part of the settlement, the company admitted to having paid $10.5 million in bribe payments between 2011 and 2016 in order to retain and obtain contracts in Brazil, Mexico, and Argentina. According to the U.S. Department of Justice, Stericycle earned approximately $21.5 million in profits from the scheme.