Pharmaceuticals /Medical Devices /Health

Corporate Headquarters

Lake Forest, Illinois, United States

Summary of Allegations:

Nationality of Foreign Officials: Brazil

Summary of Allegations:

The SEC and DOJ are reportedly investigating Stericycle's compliance with the Foreign Corrupt Practices Act and other anticorruption laws with respect to the Company’s operations in Latin America.

Approximate Alleged Payments to Foreign Officials:

Business Advantage Allegedly Obtained:

Enforcement Results

Agencies: United States: Department of Justice, United States: Securities and Exchange Commission

Results: Compliance Monitor, Criminal Penalty, Deferred Prosecution Agreement

Year Resolved: 2022

Compliance Monitor:

Ongoing: No


On August 11, 2017, Stericycle revealed it had received a subpoena from the SEC “relating to the Company’s compliance with the Foreign Corrupt Practices Act ('FCPA') or other foreign or domestic anti-corruption laws with respect to… the Company’s operations in Latin America” and that “[t]he Department of Justice has notified the Company that it is investigating this matter in parallel with the SEC.”

On 25 February 2022, Stericycle disclosed that is currently working on an agreement with the DOJ and SEC. The company said it would pay nearly $81 million in total to the DOJ and the SEC to resolve FCPA probes. The agreement is still subject to final approval by the company's board, as well as the DOJ and the SEC.

On 18 April 2022, Stericycle entered into a three-year deferred prosecution agreement with the DOJ in connection with the company's criminal charges of conspiracy to violate the anti-bribery provision of the FCPA, as well as the books and records provisions. The DOJ set a criminal penalty of $52.5 million, the department has agreed to credit up to one-third of the criminal penalty against fines the company pays to authorities in Brazil in related proceedings. The company has also agreed to pay approximately $28 million to resolve a parallel investigation by the U.S. Securities and Exchange Commission (SEC) and will engage an independent compliance monitor for two years. 

  • Stericycle