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Anticorruption Enforcement in Brazil

By Alex Bracket and Ryan Bonistalli
November 02, 2015

Brazil's push to fight corruption has been steadily gaining steam over the last year, as the wide-ranging Petrobras scandal has continued to pull politicians and companies from across Brazil and beyond under its wheels. These parallel spectacles of corporate and political intrigue seem to spawn a new headline every day. Now the Petrobras scandal ' which involves contracts worth billions of dollars ' may become increasingly multinational as prosecutors have announced a U.S. connection that could make the U.S. Department of Justice (DOJ) and Securities and Exchange Commission (SEC) active participants. Meanwhile, the public is outraged and has called for President Dilma Rousseff's impeachment, as the speaker of Brazil's lower house of Congress and a former president of Brazil face recently-filed corruption charges.

In light of this cascading wave of anti-corruption enforcement, companies operating in Brazil and beyond would be wise to scrutinize the adequacy of their corporate compliance programs. Fortunately, recent regulations further implementing Brazil's Clean Company Act provide guidance that will help them move forward with confidence.

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