According to the terms of a superseding information made public by the U.S. Attorney’s Office for the Southern District of New York on or about February 13, 2024, Mauricio Gomez Baez (“Baez”)—a former Stericycle executive for Latin America—was officially charged with a single count of  conspiracy for his role in a multi-year scheme to expand Stericycle’s business opportunities in the Latin American region (particularly, Mexico,...

In following the Justice Department and the Securities Exchange Commission FCPA enforcement actions, I am always reminded of the popular phrase — “reading the tea leaves.” (or “tasseography,” a fortune-telling method based on tea leave patterns in tea sediments).  Despite a slow initial year in 2021, the Biden Administration’s stamp and push on FCPA enforcement is becoming clear.  Keep in mind, DOJ and SEC officials...