Stericycle Inc. is a company that specializes in the waste management of regulated materials, like medical or pharmaceutical waste. The company is based in Illinois but has many facilities around the world. As part of its business, Stericycle enters into contracts with foreign governments to handle their hazardous wastes. Unfortunately, some of these contracts have been formed under illegal means.
In April of 2022, Stericycle agreed to settle a case brought by the Department of Justice (DOJ), the Securities and Exchange Commission (SEC), and foreign authorities. The allegations state that the company had offered bribes to foreign officials from Mexico, Argentina, and Brazil, in exchange for government contracts in those countries. According to the evidence, the company had paid approximately $10.5 million in bribes and got more than $20 million from the contracts it received. The bribes were paid through a system of fake vendors and falsified invoices, which the company could not detect due to insufficient compliance checks.
The case was brought forward using the Foreign Corrupt Practices Act (FCPA), which prohibits the offering of bribes to foreign officials in exchange for unfair business advantage. The FCPA covers all types of bribes, from offering money to paying for meals and entertainment. The statute also contains a whistleblower provision, allowing people, including non-US citizens, to bring information regarding bribery to the corresponding authorities. If the information provided leads to a successful settlement, the whistleblower is entitled to receive a percentage of that settlement as a reward. It is unclear whether a whistleblower assisted the government in its case against Stericycle, but if they did, they could receive millions of dollars as a reward for their efforts.
Do you have a valid claim?
If you witnessed any widespread suspicious activity within your workplace, you might have a chance of becoming a whistleblower by reporting an ongoing fraudulent scheme. However, to increase your chances of success, you must be sure to back up your claim with substantial evidence or privileged information.
A Quick Whistleblower Checklist
Is the fraudulent scheme widespread enough?
Has the fraud been perpetuated for years or involves large sums of money?
Do you possess any physical evidence of the fraud (documents, forged signatures)?
Do you have access to privileged information which may help our investigators?
Do you work as an insider within the company perpetrating the fraud?
Did you witness any ongoing illegal behavior within your workplace?
Have you been forced into taking part in any suspicious corporate activity?
