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Alexandra Wrage
President and Founder, TRACE

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Nicola Bonucci 
International Lawyer and former
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Dave Lee
FCPA Compliance Consultant, TRACE
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Sunny McCall
Senior Director II, Compliance Training, TRACE
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Lee Nelson
Independent Compliance and
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Jessica Tillipman
Associate Dean for Government Procurement Law, The GW University Law School
  • Writer's pictureJames Koukios

Stericycle, Inc.

Stericycle logo

On February 27, 2024, Mauricio Gomez Baez, a former Senior Vice President of international waste management company Stericycle, Inc., pleaded guilty to one count of conspiracy to violate the FCPA’s anti-bribery provisions.[3] Gomez Baez, a citizen of Mexico and resident of Miami, Florida, worked for the company’s Latin American headquarters in Miami.[4] From 2011 to 2016, Gomez Baez and others allegedly coordinated payments of roughly $10.5 million in bribes to government officials in Mexico, Brazil, and Argentina to obtain government contracts for medical waste collection, resulting in approximately $21.5 million in profits for the company. In each of these alleged schemes, Gomez Baez and others typically generated spreadsheets with false transactions and used code words to discuss the bribes. Under the terms of the Plea Agreement, Gomez Baez faces a term of imprisonment of up to five years, a supervised release term of up to three years, and a fine of up to $250,000, along with any additional forfeiture and restitution that the court orders. This criminal charge follows Stericycle’s April 2022 resolutions with the U.S. Department of Justice (DOJ) and U.S. Securities and Exchange Commission (SEC) for related conduct.



Partner and Co-Head of the FCPA and Global Anti-Corruption Practice, Morrison Foerster

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