FCPAméricas Blog
Merrill Brink Publishes English Translation of Brazil’s Integrity Program Guidelines
10.30.2015
Earlier this month, FCPAmericas described the guidelines that Brazil’ Office of the Comptroller General (CGU) issued clarifying the elements of compliance programs set forth in the Clean Companies Act. Merrill Brink International has now published an English translation of the guidelines. The English translation can be found here... Read more
Brazilian Government Issues Compliance Program Guidelines
10.11.2015
On September 22, 2015, the Office of the Comptroller General (CGU) issued guidance entitled Compliance Programs – Guidelines for Private Companies (Programa de Integridade: Diretrizes para Empresas Privadas) (“CGU Guidance”) clarifying the elements of compliance programs set forth in the Clean Companies Act and further regulated by Decree 8.420/2015 (further discussed here , here, and here... Read more
Will Brazil Slide Backwards in Its Anti-Corruption Efforts?
9.29.2015
By Carlos Ayres and Bruno Maeda
The Office of the Comptroller General (CGU) is one of the essential bodies of the Brazilian government to fighting corruption. It is the body of the federal government responsible for auditing federal expenditures, promoting transparency, representing Brazil on international anti-corruption forums (i.e., OECD, OEA and UN), and sanctioning public employees involved in wrongdoing. Moreover, under Brazil’s Clean Companies Act, the CGU has authority to investigate and apply administrative sanctions for the illegal acts committed against foreign public administrations. In the case of bribery of local officials at the Federal Executive branch level, the CGU has concurrent authority to initiate administrative proceedings against legal entities and to examine and correct proceedings handle... Read more
