FCPAméricas Blog

Brazil Issues New Regulations on the Clean Companies Act

Author: Carlos Ayres

diaro oficialOn March 18, 2015, President Dilma Roussef signed Decree 8.420/2015, which regulates certain features of the Clean Companies Act. The highlights of Decree 8.420/2015 are available here.

On April 7, 2015, the Office of the Federal Comptroller General (“CGU“), the body with authority to in... Read more

Best Practices for Setting Up a Hotline

Author: Carlos Ayres

Hotline2A hotline is an important element of a compliance program. The Resource Guide to the FCPA mentions that “an effective compliance program should include a mechanism for an organization’s employees and others to report suspected or actual misconduct or violations of the company’s policies on a confidential basis and without fear of retaliation”. Similarly, the Brazilian regulation on compliance programs sets forth that the existence of a hotline available to employees and third parties is one of the elements that will be taken into consideration when authorities evalu... Read more

Antitrust Enforcement Trends in Latin America

Author: Guest Author

CollusionBy: Ana Paula Martinez, Mariana Tavares de Araujo

With so much emphasis in Latin America lately on the enforcement of anti-corruption laws like the FCPA, companies should not lose sight of the fact that antitrust enforcement in countries like Brazil, Chile, Colombia, Mexico, and Peru is now well-established as well.

For example, since Brazil’s current competition law entered into force in 2012, the enforcement body CADE has issued guilty verdicts in approximately 50 investigations of anticompetitive conduct. It has conducted “dawn raids” in 15 cases since 2010. Defendants in cartel cases have been fined, on average, 15% of their annual gross revenues. Those found to have abused their dominant positions in the market have been fined roughly 5%. A record fine of U... Read more


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