Stericycle Executive Charged in Latin Bribery Scheme

A federal grand jury in the Southern District of Florida returned an indictment March 18 charging a former finance director of the Latin America division of Stericycle Inc., an international waste management company headquartered in Lake Forest, Illinois, for his role in an alleged scheme to pay over $10 million in bribes to foreign officials in Brazil, Mexico, and Argentina.

According to court documents, between 2011 and 2016, Abraham Cigarroa Cervantes, 51, of Mexico, and others allegedly caused hundreds of bribe payments to be made to government officials in Brazil, Mexico, and Argentina to obtain and retain business and to secure improper advantages for Stericycle, a U.S. securities issuer, in connection with providing waste management services.

As part of the scheme, employees at Stericycle’s offices in Mexico, Brazil, and Argentina allegedly made bribe payments, typically in cash, and calculated the amount of the bribes as a percentage of underlying contract payments made by or owing from a government customer.

In all three countries, Cigarroa and his co-conspirators allegedly tracked the bribe payments through spreadsheets and described the bribes through code words and euphemisms. To conceal the corrupt payments, Cigarroa and others allegedly maintained false books, records, and accounts that did not accurately and fairly reflect the transactions and dispositions of Stericycle’s assets, causing Stericycle to falsely record bribe payments as legitimate expenses in its consolidated books, records, and accounts.

Cigarroa also allegedly submitted and maintained falsified Sarbanes-Oxley certifications and business unit representation letters falsely attesting that the books, records, and accounts were accurate.

Cigarroa is 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. If convicted, he faces a maximum penalty of five years in prison on each count.

In April 2022, Stericycle admitted to bribing officials in Mexico, Brazil, and Argentina in violation of the FCPA’s anti-bribery and books and records provisions. Stericycle entered into a three-year deferred prosecution agreement with the Criminal Division’s Fraud Section and agreed to pay more than $84 million as part of a coordinated resolution with the Justice Department, the Securities and Exchange Commission, and authorities in Brazil.