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Episode 234 -- A Deep Dive into the Stericycle FCPA Enforcement Action

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内容由Volkov Law提供。所有播客内容(包括剧集、图形和播客描述)均由 Volkov Law 或其播客平台合作伙伴直接上传和提供。如果您认为有人在未经您许可的情况下使用您的受版权保护的作品,您可以按照此处概述的流程进行操作https://zh.player.fm/legal

The Justice Department ended its FCPA enforcement drought by announcing its first corporate settlement in 2022. In a parallel action, the SEC announced its settlement with Stericycle for $28 million for FCPA violations. The SEC’s settlement was its second with a company for 2022 (the first was KT Corp.).

Under the settlement, Stericycle resolved investigations being conducted by the Department of Justice, the Securities and Exchange Commission and Brazil. Stericycle agreed to enter into a three-year deferred prosecution agreement and pay more than $84 million. Stericycle will pay $52.5 million in criminal penalties, $28 million to the SEC in civil penalties and disgorgement, and approximately $9.3 million to Brazilian authorities. DOJ agreed credit up to one-third of the criminal penalty against fines the company pays to Brazil authorities.

Significantly, the DPA requires Stericycle to obtain an independent compliance monitor for a two-year period and then submit a self-report for the rest of the DPA term.

Stericycle is a global waste management company which is headquartered in Illinois. In its factual admission, Stericycle admitted a wide ranging scheme involving payment of bribes to foreign officials in Brazil, Mexico and Argentina. In total, Stericycle paid approximately $10.5 million in bribes to foreign officials in Brazil, Mexico and Argentina to secure business contracts from which Stericycle profited by at least $21.5 million.

In this Episode, Michael Volkov reviews the Stericycle FCPA enforcement action.

  continue reading

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Manage episode 327857712 series 1587876
内容由Volkov Law提供。所有播客内容(包括剧集、图形和播客描述)均由 Volkov Law 或其播客平台合作伙伴直接上传和提供。如果您认为有人在未经您许可的情况下使用您的受版权保护的作品,您可以按照此处概述的流程进行操作https://zh.player.fm/legal

The Justice Department ended its FCPA enforcement drought by announcing its first corporate settlement in 2022. In a parallel action, the SEC announced its settlement with Stericycle for $28 million for FCPA violations. The SEC’s settlement was its second with a company for 2022 (the first was KT Corp.).

Under the settlement, Stericycle resolved investigations being conducted by the Department of Justice, the Securities and Exchange Commission and Brazil. Stericycle agreed to enter into a three-year deferred prosecution agreement and pay more than $84 million. Stericycle will pay $52.5 million in criminal penalties, $28 million to the SEC in civil penalties and disgorgement, and approximately $9.3 million to Brazilian authorities. DOJ agreed credit up to one-third of the criminal penalty against fines the company pays to Brazil authorities.

Significantly, the DPA requires Stericycle to obtain an independent compliance monitor for a two-year period and then submit a self-report for the rest of the DPA term.

Stericycle is a global waste management company which is headquartered in Illinois. In its factual admission, Stericycle admitted a wide ranging scheme involving payment of bribes to foreign officials in Brazil, Mexico and Argentina. In total, Stericycle paid approximately $10.5 million in bribes to foreign officials in Brazil, Mexico and Argentina to secure business contracts from which Stericycle profited by at least $21.5 million.

In this Episode, Michael Volkov reviews the Stericycle FCPA enforcement action.

  continue reading

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