Stericycle was alleged to have caused hundreds of bribes to be made to government officials in Brazil, Mexico, and Argentina to boost its business there. For example, an executive at Stericycle’s Latin America division directed employees to pay bribes in cash that were a percentage of the proceeds Stericycle got from government customers (this is often referred to as a ‘kickback’). People involved in the bribes then tracked the payments through spreadsheets and described the bribes through code words such as “alfajores,” which is a popular cookie in Latin America.
The announcement of the settlement and the posting of a notice of covered action will start the clock ticking for any SEC whistleblower who provided information regarding the scheme to file a form WB-APP with the SEC in order to claim a whistleblower reward. As FCPA whistleblowers can claim up to 30% of the total fine, this means there is a potential for a payout of almost $30 million at stake.
John Joy is the Managing Attorney and founder of FTI Law, a law firm that specializes in representing FCPA whistleblowers. John is a New York based FCPA whistleblower attorney who has worked for almost a decade on FCPA and corruption cases around the globe. Prior to founding FTI Law, John worked at an elite international law firm in New York and London representing clients in multi-national investigations before the DOJ, SEC, FINRA, FCA & SFO. John is one of the few whistleblower attorneys with extensive international experience working with Fortune 500 corporations who are often the subject of whistleblower complaints.