Month in a Minute: July 2026

Hughes Hubbard’s anti-corruption “Month in a Minute” offers a quick snapshot of the key foreign corruption-related developments from the prior month. We hope you find it a useful and perhaps enjoyable resource.

Below are some highlights from July, which include time served for a former Stericycle director, a resolution with the U.S. Department of Justice for a U.S. agricultural company and a guilty verdict in the trial of an ex-Goldman Sachs banker.

Former Stericycle Finance Director Sentenced to Time Served

On July 10, Abraham Cigarroa Cervantes (Cigarroa), a former finance director at Stericycle’s Latin American branch, was sentenced to time served for his involvement in a scheme to bribe government officials in Brazil, Mexico and Argentina.

According to an indictment issued on March 19, 2024, between December 2011 and April 2016, Cigarroa and his co-conspirators paid approximately $10.5 million in bribes to officials in Brazil, Mexico and Argentina to help Stericycle obtain government contracts for medical waste collection. Cigarroa and his co-conspirators concealed the bribe payments by making false entries in Stericycle’s books and records. They also tracked the bribe payments through spreadsheets using code words such as “IP” and “advanced payments.”

Cigarroa initially pled not guilty on April 24, but later pled guilty to one count of conspiracy to violate the Foreign Corrupt Practices Act (FCPA) on May 21. In addition to time served, Cigarroa was sentenced to three years of supervised release and a fine of $225,000. This was a lower sentence than the 17-month incarceration prosecutors recommended to U.S. District Judge Kathleen Williams.

In connection with the same scheme, a former Stericycle senior vice president, Mauricio Gomez Baez, pled guilty in February 2024 to one count of conspiracy to violate the anti-bribery provisions of the FCPA. In addition, Stericycle entered into a DPA in April 2022 to resolve parallel investigations by the DOJ and the U.S. Securities & Exchange Commission and agreed to pay more than $80 million in penalties and disgorgement.

Scoular Pays $10M To Resolve FCPA Investigation

On July 17, the DOJ announced that the Scoular Co., an Omaha-based agricultural supply chain company, entered into a three-year DPA for allegedly paying bribes to Mexican officials to facilitate Scoular’s shipments across the U.S.-Mexico border.

A criminal information filed on July 7 in the Western District of Texas charged Scoular with one count of conspiracy to violate the anti-bribery provisions of the FCPA, and it alleged that between 2013 and 2019 Scoular used customs brokers to transport corn and other products into Mexico. The brokers paid Mexican border officials approximately $2,000 per train to permit the shipments to proceed, with the payments subsequently invoiced to Scoular as “reinspection fees,” which Scoular reimbursed. A portion of the payments ultimately benefited individuals associated with a cartel operating at the U.S.-Mexico border, although the DOJ determined that Scoular and its employees were unaware of that connection. In total, Scoular paid an estimated $400,000 in bribes and avoided more than $6.5 million in costs and fees.

Under the terms of the DPA, Scoular agreed to pay a criminal penalty of $9.7 million and forfeit more than $400,000, for a total payment exceeding $10 million. Scoular did not receive voluntary disclosure credit under the DOJ’s Corporate Enforcement and Voluntary Self-Disclosure Policy because it did not voluntarily and timely disclose the conduct. However, Scoular received credit for its cooperation and remediation efforts, which included conducting an internal investigation, providing information to the DOJ, implementing the findings of an external compliance maturity assessment and eliminating the use of customs brokers associated with reinspection fees in Mexico. Because of these efforts, the criminal penalty Scoular must pay reflects a 25% reduction from the applicable U.S. sentencing guidelines range.

As part of the DPA, Scoular also agreed to continue cooperating with the DOJ in ongoing or future investigations, committed to implementing an anti-corruption compliance and ethics program, and must regularly report to the DOJ concerning its compliance measures.

The DOJ’s press release emphasizes the heightened FCPA risk facing U.S. companies engaged in cross-border business with Mexico. As the U.S. attorney for the Western District of Texas warned, “Nothing crosses into or out of Mexico without the approval and payment to Mexican drug cartels. American businesses that engage in any cross-border trade bear a significant amount of responsibility to do so without benefitting those cartels and without threatening our national security.” The statement reflects the enforcement priority the DOJ has placed since 2025 on FCPA matters involving Mexican criminal organizations and cautions U.S. businesses to scrutinize whether their operations or payments could directly or indirectly benefit such organizations.

Ex-Goldman Sachs Banker Tried and Found Guilty

On Aug. 6, a federal jury in the Eastern District of New York found Asante Kwaku Berko, a former executive director in Goldman Sachs’ Investment Banking Division, guilty of conspiracy to violate the FCPA, substantive FCPA violations and conspiracy to commit money laundering. The verdict came after a nine-day trial, which began on July 28.

Between December 2014 and March 2017, Berko and his co-conspirators paid more than $700,000 in bribes to officials at the Ghanian Ministry of Power and other government entities in exchange for securing a power plant project for a Goldman client, Turkish energy company Aksa Enerji (Aksa). Berko and his co-conspirators then received reimbursement for those payments by issuing false invoices to Aksa for “consultancy services.” The project was expected to generate millions of dollars in revenue and a projected $11 million in fees for Goldman Sachs and $2 million for Berko himself.

The guilty verdict comes after Berko resolved a lawsuit brought against him by the SEC stemming from the same conduct in June 2021. As part of his resolution with the SEC, Berko agreed, without admitting or denying the allegations, to disgorge $275,000 and pay $54,000 in prejudgment interest. His sentencing date has not been set. For additional information on Berko’s case, please see our June 2024 Month in a Minute.

Fact of the Month

“If the radiance of a thousand suns were to burst at once into the sky, that would be like the splendor of the mighty one.” This verse from the Bhagavad-Gita was recalled by J. Robert Oppenheimer when, on July 16, 1945, the Manhattan Project conducted the first successful nuclear bomb test in the Jornada del Muerto desert in New Mexico. Labeled the “Trinity Test,” the test was of a plutonium bomb, the design of which was later nicknamed “Fat Man.” The explosion carried the energy of 25,000 tons of TNT and generated a fireball more than 200 meters in height. The life of Oppenheimer and the Trinity Test have since been the subject of the Pulitzer Prize-winning biography “American Prometheus” (2005) by Kai Bird and Martin J. Sherwin and the multiple Oscar-winning film “Oppenheimer” (2023) directed by Christopher Nolan.