FCPAméricas Blog

Political Donations in Brazil Declared Unconstitutional: compliance considerations for upcoming elections

Author: Guest Author

ballotboxThis guest post is by Trevor Schumacher, a Sao Paulo-based partner of the Financial Advisory area of Deloitte, and Viviane Viera Coutinho Rocha, a Senior Consultant of Deloitte’s Financial Advisory area.

Until recently, legal entities operating in Brazil were permitted to make political donations provided they complied with the requirements of Law 9.504 (9.504/97, arts. 23, § 1º, I e II, § 7º e 81, § 1º) and the rules set forth in Resolution 23.376, Instruction 1542-64.2011.6.00.0000.The law and related resolution permitted legal entities to donate up to 2% of gross income earned in the prior calendar year. Companies and poli... Read more

PDVSA at the Center of International Anti-Corruption Efforts

Author: Matteson Ellis

ve$pdvsaThis post was co-authored by Maryna Kavaleuskaya, a Law Clerk at Miller & Chevalier.

How do multiple enforcement authorities from different countries hold one of the largest petroleum producers in the world accountable for years of institutionalized corruption? Press reports on investigations of Venezuela’s state-owned oil company, Petroleos de Venezuela S.A. (“PDVSA”), suggest several answers. Authorities go after the company’s former leaders who reside outside of Venezuela. They... Read more

FCPAméricas Interviews The Chair of the OECD Working Group on Bribery

Author: Carlos Ayres

KosDrago Kos, the Chair of the OECD Working Group on Bribery, leads the Group in its monitoring and evaluation of the laws implementing the OECD Anti-Bribery Convention by its Parties. He recently told FCPAméricas what to expect about the Phase 4 Evaluation (previous phases are discussed here), where Latin America fits in the fight of bribery of foreign public officials and key achievements of the OECD-Latin America Anti-Corruption Programme:

What are the pillars of the OECD Anti-Bribery Convention’s Phase 4 Evaluation?

In the upcoming Phase 4 Evaluation we will assess our member states’ efforts and results in the following areas:

progress on the implementation of outstanding recommendations from previous phases,... Read more


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