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Government Enforcement Exposed - "The GEE"
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23 Apr 2015 FCPA / BRAZIL: THE PERFECT STORM FOR ANTI-CORRUPTION ENFORCEMENT

With ever increasing pressure on its government to stamp out corruption, Brazil presents a “Perfect Storm” for Foreign Corrupt Practices Act (FCPA) / Anti-Corruption enforcement approaching the 2016 Olympics. Having the Olympic Games centered in Rio de Janeiro presents the perfect opportunity for Dilma Rousseff’s government to show that it takes enforcement of anti-corruption laws seriously. As such, companies should ensure their compliance initiatives are being vigorously updated and monitored. This is especially the case with regard to third-party relationships.   While passage of the Clean Companies Act (CCA) brought Brazil in line with an ever growing international consensus against corruption, the CCA has been sparingly enforced. Though the CCA penalizes both corporations and individuals for corrupt conduct, implementing regulations called for by its passage…

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25 Feb 2015 PART II – CORRUPTION ENFORCEMENT IN BRAZIL: WHAT DOES THE FUTURE HOLD?

The anti-corruption regulatory environment in Brazil has become more risky and complex during the CCA era. Do enforcement trends foreshadow eventual robust application of the CCA? The number of recent high profile cases brought against individuals in Brazil strongly suggests a climate with little tolerance for bribery. What was historically commonplace within Brazilian economic and political spheres may no longer be the norm. Indeed, in taking the oath of office for her second term as President on Jan. 1, 2015, Dilma Rousseff promised to embark on an anti-corruption crusade in response to the corruption scandal engulfing Petrobras. She went further in pledging to forward the Brazilian legislature an anti-corruption bill during the first half of 2015 and to lead the Brazilian political system in a…

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23 Feb 2015 PART I – CORRUPTION ENFORCEMENT IN BRAZIL: WHAT DOES IT LOOK LIKE?

Anti-corruption enforcement in Brazil has experienced an uptick over the past year. Enforcement of the Clean Companies Act (CCA) is having an impact in both the Brazilian business and political spheres. The future of Brazilian’s anti-corruption enforcement, together with anticipated new legislation and regulations in this area dictates that companies doing business in Brazil take heed and consider enhanced compliance efforts to ensure business activity stays within the bounds of the CCA and any expanded enforcement efforts.   While Brazil is the world’s fourth largest democracy, it has been saddled in recent years by multiple corruption scandals. Transition of the political landscape in Brazil to one of democracy in 1985 increased hope for greater transparency. Each of the six (6) presidential administrations since, however, has…

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