Compliance and Investigations: 2025 Overview

It covers, among other topics, government investigations and the main developments involving the CGU throughout the year – including the milestone of 100 administrative accountability proceedings (PARs) initiated in a single year and the release of data on the methodology used to calculate sanctions under the Brazilian Anti-Corruption Law. It also summarizes developments in leniency agreements and ongoing debates before the Brazilian Supreme Federal Court (STF) regarding institutional jurisdiction, as well as updates related to Pró-Ética, parameters for assessing integrity programs in public biddings, and interpretive statements on the Brazilian Anti-Corruption Law.

From an international standpoint, we highlight changes announced by the U.S. Department of Justice (DOJ) to its FCPA enforcement policy and the growing relevance of sanctions, with repercussions in Brazil.

This newsletter provides information about legal developments in Brazil to clients and members of Cescon, Barrieu, Flesch & Barreto Advogados. The content included herein is not meant to provide legal advice with respect to any specific matter. We do not undertake to update, supplement or modify the information contained herein.

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