Tagged: Lessons learned Stericycle

Stericycle DOJ and SEC FCPA Settlement: Lessons Learned (Part III of III)

Stericycle DOJ and SEC FCPA Settlement: Lessons Learned (Part III of III)

The Stericycle FCPA case is yet another example of a complete culture and compliance breakdown.  As I often repeat myself, there is no more important control than an ethical culture.  When a culture veers into the unethical and even criminal conduct, there is nothing to stop that train of illegality from continuing. When you review the facts of Stericycle’s conduct in Brazil, Mexico and Argentina,...