Since the Monaco Memo came out in late 2021 there have been scant DOJ settlements in general and none in the FCPA space. That changed in late April 2022 when Stericycle, Inc., announced that it had settled bribery allegations with the DOJ, SEC and Brazilian authorities. The underlying facts are old-school bribery – cash handed over to government officials in Brazil, Mexico and Argentina, tracked on Excel spreadsheets, no less – but the settlement terms offer some clues on how the Monaco Memo will be implemented. We attempt to read the enforcement tea leaves as well as tease out a few compliance lessons for companies. For more on DOJ enforcement changes in the works, see “Can Compliance Certifications Empower CCOs?
” (Apr. 27, 2022).