FCPAméricas Blog

Brazilian Office of The Comptroller General takes Another Step Forward In Combating Corruption

Author: Guest Author

CGUBrazilMichel Sancovski is an Associate attorney at Trench, Rossi e Watanabe Advogados.

Since January 29, 2014, when the Clean Companies Act came into force, the Brazilian Office of the Comptroller General (Controladoria Geral da União – CGU) has consistently increased its efforts to combat and prevent corruption and bribery.

Recently, the CGU took another important measure. On April 28, 2016, CGU enacted Directive No. 784 (Portaria No. 784), which creates the Program to Promote Integrity in Public Service (Programa de Fomento da Integridade Pública – PROFIP). This program aims to guide and enable the federal administration, including its agencies and foundations, in creating Integrity Programs — the name given... Read more

The Panama Papers: What U.S. Enforcement Could Look Like

Author: Guest Author

PanamaFlagThe following guest post is from Timothy O’Toole, a Member of Miller & Chevalier who focuses on sanctions, export controls, and other international regulatory and compliance issues.

The Panama Papers have recently become a worldwide, front-page news story, in the wake of reports from the International Consortium of Investigative Journalists (ICIJ) describing the alleged involvement of a number of individuals in offshore bank accounts. But while the reports have generated significant news coverage, the remaining question is whether they will also generate enforcement actions. The answer is likely yes.

Indeed, a virtual roadmap for such investigations already exists, with U.S. regulators and prosecutors having recently targeted the Swiss banking system, and in particular the use of secret accounts there. These actions have largely been brought pursuant to U.S. criminal tax laws under theories that Swiss ban... Read more

Ten Measures Proposed by the Brazilian Federal Prosecution Service to Fight Corruption (Part II)

Author: Carlos Ayres

Thimage001e Brazilian Federal Prosecution Service launched a campaign last year to close ranks on corruption, proposing ten measures. The initiative is known as 10 Measures Against Corruption and, as of March 25, 2016, it had obtained 2,028,263 petitions from supporters around the country. On March 30th, it was delivered to Congress as a bill of law by popular initiative and will now follow the legislative process. In a previous post, the 5 first measures were presented. The remaining 5 measures are summarized below.

6) Reform of statute of limitations rules. The sixth measure increases the statute of limitations period in one third and makes other changes to the commencement and calculation of the statute of limitations. According to the Federal Prosecution Services, many individuals get away from criminal convictions because the current statute of limitations rules are very favorable to them.

7) Adjustments in criminal nullity ... Read more


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