Compliance and Investigations: Year in Review 2025

The year of 2025 was marked by significant changes in the global and national compliance landscape. Below, we present the key events of the year, regulatory developments, and institutional initiatives that had impacts on companies and public agencies, highlighting challenges and opportunities to strengthen integrity practices.

Expansion of Anti-Corruption Policies

In the beginning of the year, the Office of the Comptroller General (CGU) launched the Integrity and Anti-Corruption Plan 2025–2027, comprising 260 strategic actions aimed at transparency and the prevention of illicit practices. This initiative reflects a global trend, mirrored by countries such as China, which has intensified investigations in critical sectors, reinforcing the need for robust internal controls within companies.

Changes in the United States

In the United States, two measures drew attention: the expansion of whistleblower rewards by the SEC, encouraging anonymous reports with awards ranging from 10% to 30% of the sanctions imposed, and the temporary suspension of FCPA enforcement by executive order of President Donald Trump. This pause sparked international criticism and was later reversed with the publication, by the Department of Justice, of new guidelines on the prioritization of FCPA’s enforcement, with a focus on national security, protection of U.S. competitiveness, and prevention of transnational criminal organizations.

Brazilian Scenario

In Brazil, the Corruption Perception Index reached its worst result since 2012, reflecting institutional weaknesses and controversial judicial decisions. Nevertheless, the Office of the Comptroller General (CGU) maintained significant efforts, such as imposing sanctions on companies for pandemic-related fraud and intensifying operations across several states, including asset freezes and holding managers accountable.

International Cooperation and New Standards

International cooperation gained momentum with the creation of an anti-corruption task force involving France, the United Kingdom, and Switzerland, as well as the BRICS initiative under Brazilian leadership, which incorporated topics such as sustainability and the use of artificial intelligence in combating corruption. Within the European Union, a provisional agreement established minimum standards for defining and penalizing corrupt offenses, harmonizing rules among Member States.

Regulation and Corporate Compliance

The year also brought significant regulatory developments: in Brazil, the Office of the Comptroller General (CGU) issued an ordinance for assessing integrity programs in large-scale public procurement, while in the United Kingdom, the corporate offense of “Failure to Prevent Fraud” came into effect, with extraterritorial reach and a requirement for robust procedures to prevent fraud.

Law Enforcement Operations and Structured Investigations

Major operations marked the year, such as Hidden Carbon, which dismantled a billion-dollar money laundering scheme in the fuel sector, and Zero Compliance, which uncovered financial fraud involving banking institutions. These cases highlight systemic risks and the need for effective internal controls to mitigate reputational and regulatory impacts.

Trends and Challenges

Discussions on artificial intelligence in public security, new rules for anti-money laundering for the bets’ sector, and the strengthening of international cooperation indicate that compliance has evolved beyond a mere legal obligation to become a competitive and strategic advantage. Companies that invest in integrity, technology, and sustainability will be better positioned to manage risks and seize opportunities.

January

Biennial Plan provides for the Expansion of CGU’s Operations

The Office of the Comptroller General (CGU) launched the 2025-2027 Integrity and Anti-Corruption Plan, which brings together 260 strategic actions to promote integrity and combat corruption in the federal public administration. These actions are organized into five thematic pilars, which aim to strengthen the detection, repression and deterrence of acts of corruption, in addition to promoting public and private integrity and increasing transparency.
The plan was prepared with the participation of various federal government agencies and civil society, reflecting a joint effort to address corruption in a comprehensive and effective manner. This trend is not restricted to Brazil. Recently, China has been expanding its anti-corruption investigations to include sectors such as finance, energy, and state-owned enterprises. The Central Commission for Discipline Inspection (CCDI), the country’s anti-corruption body, announced that it will step up efforts to combat corruption in various areas, following the guidance of President Xi Jinping.
These initiatives demonstrate a growing global commitment to the effective enforcement of anti-corruption laws, seeking to hold those involved in illicit practices accountable and promote integrity in different sectors of society. Companies must pay attention to this fact, not only at the national level, but also at the global level. It is essential that they are up-to-date with regulatory issues and improve their internal controls to protect themselves from possible lawsuits and ensure compliance with current regulations. For more information, click here.

U.S. Expands Chances to Reward Whistleblowers of Illegal Schemes

The United States has expanded the chances of rewards to whistleblowers who report illegal schemes, including pyramid schemes. Since 2011, the U.S. Securities and Exchange Commission (SEC) has paid out more than $2.2 billion in bounties to whistleblowers who provide information about violations of federal securities laws.
The SEC’s Whistleblower Program allows whistleblowers to receive between 10% and 30% of monetary penalties collected in successful enforcement actions. To ensure eligibility for a reward, whistleblowers must follow the rules of the SEC’s Whistleblower Program, which includes filing tips online or through a specific form. The SEC also allows whistleblowers, represented by lawyers, to submit tips anonymously.
For companies, this action by the SEC represents a significant risk, as they must always be vigilant and take preventive measures to avoid engaging in fraudulent activities. The possibility of anonymous reporting and the substantial rewards offered to whistleblowers increase the likelihood that illegal schemes will be revealed. Therefore, it is essential for companies to implement strict compliance practices, foster a culture of transparency, and conduct regular internal audits to ensure that they are compliant with laws and regulations, thereby minimizing the risks of sanctions and damage to their reputation.

February

Trump’s Decision to Suspend FCPA: Implications for Global Competitiveness and Corruption

On February 10, 2025, Donald Trump signed an executive order directing U.S. Attorney General Pamela Bondi to suspend the opening of new investigations and actions related to potential violations of the Foreign Corrupt Practices Act (FCPA) for a period of 180 days. During this time, the U.S. Attorney General should review existing FCPA-related guidelines and policies, as well as all ongoing investigations, in order to align the application of the regulation with the government’s foreign policy objectives and encourage the economic competitiveness of U.S. companies.
Trump argued that the law put U.S. companies at an economic disadvantage relative to foreign competitors, stating that many deals would not be conducted due to fear of corruption lawsuits. During the pause, the U.S. Attorney General would revise FCPA enforcement guidelines to better align U.S. economic and national security interests.
This decision was strongly criticized by international bodies, including Transparency International, highlighting that the pause would undermine the fight against global corruption, undermining decades of progress and putting international stability at risk. The organization emphasized that the FCPA was the first law in the world to prohibit bribes to foreign public officials by U.S. companies and individuals, and that suspending its application could benefit business actors with bad intentions and weaken U.S. commitments under international conventions against corruption.

Brazil worsens in Transparency International’s Corruption Perceptions Index

The new edition of Transparency International’s Corruption Perceptions Index (CPI) was published in February and brought an important portrait of the country: since 2012, Brazil has had the worst position in the ranking, falling from 104th to 107th position out of 180 countries evaluated.
The report cited the reversal of convictions in the context of Lava Jato by the Federal Supreme Court (STF) and the government’s inaction in the fight against corruption as negative factors. Transparency International also mentioned the government’s lack of anti-corruption projects throughout 2024 and what it called “maneuvers” in the Legislature to maintain the payment of parliamentary amendments with low transparency.
Transparency International also recognized the efforts of the Office of the Comptroller General (CGU) and the Federal Police in the fight against corruption, but highlighted the influence of businessmen involved in corruption, the renegotiation of leniency agreements and the maintenance in office of ministers indicted for corruption as factors that corroborated the increase in the perception of corruption.
It is important to highlight that Brazil’s placement in the Corruption Perception Index does not mean, by itself, that the country has become more conducive to acts of corruption. The CGU disclosed in a note its effort in the implementation of new projects and improvement of processes, aiming to ensure greater legal certainty and transparency. Among these, he mentioned the Transparency Portal, traceability of parliamentary amendments and the launch of the 2025-2027 Integrity and Anti-Corruption Plan.

March

Strengthening Anti-Corruption Initiatives between France, the UK and Switzerland

In a new alliance to fight corruption and international bribery, the UK’s Serious Fraud Office (SFO), France’s Parquet National Financier (PNF) and Switzerland’s Office of the Attorney General (OAG) reaffirmed their joint commitment to tackling these crimes at an event held in London.
The three agencies founded a task force to strengthen collaboration by sharing knowledge and experiences. This initiative aims to improve existing cooperation and increase efficiency in the fight against corruption and bribery in specific cases. The task force was seen as an important step toward tackling transnational economic crime and protecting future prosperity and comes shortly after the U.S. suspended enforcement of the Foreign Corrupt Practices Act (FCPA) for 6 months by the U.S. Department of Justice (DOJ).
Against this backdrop, the task force signaled greater involvement of European authorities in multijurisdictional bribery and corruption cases. Agencies can use laws with extraterritorial effect, such as the UKBA of 2010 and France’s Sapin II Act. In Brazil, the position of the Office of the Comptroller General (CGU) is one of maximum effort, since the country is leading several global initiatives and serves as a showcase in this regard.

Compliance Enforcement for Bets

The Secretariat of Prizes and Betting of the Ministry of Finance (SPA/MF) has notified all companies authorized to operate fixed-odds betting in Brazil, requiring them to present their policies for the prevention of money laundering and terrorist financing (AML/CFT).
The companies had until March 17, 2025, to comply with the Secretariat. The notifications were sent both to operators authorized directly by the Ministry of Finance and to those authorized sub judice to operate.
The measure followed the guidelines of Law No. 14,790/2023 and SPA/MF Ordinance No. 1,143/2024, which require effective actions to prevent financial crimes in the betting sector. Each AML/CFT policy must detail the criteria and actions foreseen for different occurrences, and failure to comply with these determinations may result in sanctions.
Money laundering and terrorist financing (AML/CFT) prevention policies are the first step to comply with legislation and protect companies and operators. From this document, there is enforceability both internally and externally for the implementation of adequate controls and governance to mitigate risks.

April

CGU launches new edition of the Pro-Ethics Company Program 2025-2026

The Office of the Comptroller General (CGU) presented the new edition of the Pro-Ethics Company 2025-2026 program, bringing a renewed approach and several new features. In the new edition, marked by the broadening of the spectrum of business ethics, candidates must inform whether their operations cause environmental impact or are affected by climate change, as well as how they address such risks. It will also be necessary to detail energy transition plans and policies aimed at diversity and inclusion.
The Compliance Form maintained the 10 pillars of the Compliance Program, but with an increase in the number of issues now addressed to sustainability, human rights and competition issues. Performance indicators and targets related to environmental sustainability and protection of human rights are now included alongside integrity targets. The Transparency and Social and Environmental Responsibility pillar had the largest number of innovations, focusing on the transparency of social and environmental information and integrity practices in the community. Among them, questions about the existence of a contingency plan, prevention measures to mitigate future losses, participation in collective initiatives or dissemination of actions that promote human rights, sustainable development, environmental preservation and adaptation to climate change.
In addition, in the context of competitions and the pillar of the Code of Ethics, Integrity Policies and Procedures, it will be important to demonstrate the procedures that ensure fair competition and prevention of anticompetitive practices, particularly in the context of public contracts and tenders. Companies registered on federal debt lists (including IBAMA), dirty lists or responding to PARs, leniency or monitoring were prohibited from participating.

CGU, AGU and MPF sign Technical Cooperation Agreement for Leniency

The Attorney General’s Office (AGU), the Federal Public Prosecutor’s Office (MPF) and the Office of the Comptroller General (CGU) signed a technical cooperation agreement to act jointly in the negotiation and monitoring of leniency agreements with companies involved in unlawful conduct. The objective is to speed up investigations and strengthen the fight against corruption in Brazil.
The initiative sought to encourage companies to regularize their situation before the State, facilitating access to evidence and ensuring the quick accountability of those involved, in addition to the return of the amounts embezzled to the public coffers. In leniency agreements, companies commit to collaborating with the authorities, reimbursing the public coffers and adopting ethical and sustainable practices. In return, sanctions are eased and administrative and judicial proceedings can be suspended.
 Find the main points below:

• Counters: The legal entity interested in entering into a leniency agreement must formulate the request before the CGU and/or the MPF, which will evaluate the situation presented for coordinated action. With the acceptance, the negotiation will begin with the signing of a memorandum of understanding between the AGU, the CGU, the MPF and the proposing company.

• Legal Certainty: The agreement aims to ensure legal certainty for employees, avoiding duplicity of sanctions and divergences of interpretation in the agreed terms.

• Access to Evidence: Facilitation in the exchange of information between institutions and the sharing of evidence, ensuring the confidentiality of data and the protection of employees.

• Calculation Methodology: Joint definition of methodologies for calculating the amounts of fines and compensation, based on the damages caused.

• Monitoring of Integrity Programs: Joint establishment of the parameters for evaluation and monitoring of integrity programs to be followed by companies.

• Suspension of Proceedings: If the clauses of the agreement are complied with, both administrative and judicial proceedings may be suspended.

The agreement defined the workflow and communication between AGU, CGU and MPF, ensuring the exchange of information and the confidentiality of data. The partnership will last for five years, and may be extended. Access the ACT and the respective Work Plan here.

May

BRICS Strengthens Anti-Corruption Cooperation Under Brazilian Leadership

On May 5 and 6, 2025, Brasilia hosted the meeting of the BRICS Anti-Corruption Working Group, coordinated by the Office of the Comptroller General (CGU). The meeting prioritized three main axes: the intersection between anti-corruption and sustainable development, the effectiveness of asset recovery mechanisms, and the use of artificial intelligence in the fight against illicit practices.
As a reflection of trends already underway in Brazil and in the world, the initiative highlighted a contemporary approach to compliance, which transcends mere “regulatory compliance” to encompass ethical, social and environmental aspects. In this sense, the emphasis on topics such as climate justice and environmental integrity highlighted the need for anti-corruption policies that consider socio-environmental impacts, in line with the United Nations (UN) Sustainable Development Goals (SDGs).
Concern about climate disinformation was also the subject of discussions at the forum. Another subject reinforced on the occasion was the use of artificial intelligence (AI) in the fight against corruption, which represented a significant advance and allowed greater efficiency in detecting irregularities and promoting transparency. In addition, the Brazilian National Asset Recovery Policy (PNRA), mentioned during the meeting, reinforced the importance of international cooperation in the identification and repatriation of illicit resources.

DOJ reinforces Policies to Combat Corporate Crimes with new incentives and penalties

On May 12, 2025, during SIFMA’s Annual Conference on Money Laundering and Financial Crimes, the chief of the U.S. Department of Justice’s Criminal Division presented a new strategic plan aimed at combating white-collar crimes, with a renewed focus on the priorities of the “America First” agenda.
The new approach prioritizes combating crimes that directly affect U.S. interests and national security, such as corruption, money laundering, commercial fraud, and the activities of transnational criminal organizations. Relevant changes in enforcement policies applicable to corporate and financial infractions were announced. The most significant changes and expectations include:
• expansion of incentives for self-reporting by companies, offering clearer benefits to those who collaborate voluntarily and in a timely manner;
• reformulation of the criteria used to determine the need for independent compliance monitoring; and
• expansion of guidelines related to the performance of whistleblowers.
In this sense, rules were established to reduce the rush for self-denunciations to the Department, with defined deadlines to guarantee benefits even when the DOJ is already aware of the facts. Finally, the whistleblower rewards program was expanded, covering new categories of infractions and reinforcing the importance of internal Compliance programs.

June

New FCPA Guidance Published by U.S. Department of Justice

On June 9, 2025, the U.S. Department of Justice (DoJ) published a new guideline regarding Executive Branch Order No. 14209, of February 10, 2025, which temporarily suspended the application of the Foreign Corrupt Practices Act (FCPA) for 180 days.
In line with the objectives of the Order, this new Guideline focuses on (i) the total elimination of cartels and transnational criminal organizations (“TCOs”); (ii) ensuring fair opportunities for U.S. companies; (iii) advancement of the country’s national security; and (iv) prioritization of investigations of serious misconduct.
As a result, the DoJ will take the following independent actions when enforcing the FCPA:

a.Prioritize investigations related to foreign bribery associated with criminal operations of cartels and TCOs that use money laundering schemes for such entities or are related to officials of state organizations or public officials who have received bribes from cartels/TCOs.

b.identify and prioritize investigations of facts that hinder economic growth and expansion of business opportunities abroad to the U.S., not necessarily against companies and individuals of specific nationalities. In this regard, when applying the Foreign Extortion Prevention Act (“FEPA”), which criminalizes the “demand side” of foreign bribery, prosecutors must consider whether U.S. entities or individuals have been harmed by the demand for bribes by foreign officials.

c.focus on threats deemed most urgent to U.S. national security resulting from bribery of corrupt foreign officials involving infrastructure or critical assets. This includes critical minerals, deep-water exploration, among others.

d. not focus, in principle, on routine commercial diversions or business conduct aimed at commonly accepted/low-cost hospitality, but rather on conduct with strong indications of corrupt intent linked to specific individuals, such as representative amounts of bribes, proven/sophisticated efforts to conceal bribe payments, fraudulent conduct in support of the bribery scheme, and efforts to obstruct justice.

The ongoing cases now suspended would already be reviewed (and eventually closed) in light of these new guidelines. At the same time, the opening of new FCPA cases was subject to the authorization of the Deputy Attorney General of the Criminal Division of the DoJ or higher, respecting those guidelines. It is worth noting that the guidelines in question do not clarify the end of the suspension imposed by the Federal Executive
 In addition, the DoJ will consider (i) whether or not there is interest in pursuing cases that have already been judicialized or not yet; as well as (ii) the likelihood (or lack thereof) that the foreign authority also responsible is willing and able to investigate and prosecute the same alleged misconduct.
The guidelines make transparent the approach of preserving U.S. domestic interests in the application of the FCPA and preserving the business of U.S. companies. Access the Memorandum here.

CGU Maintains Sanctions on Companies for Fraud in the Pandemic

The Office of the Comptroller General (CGU) published two decisions related to irregularities in the fight against the Covid-19 pandemic: one involving overbilling in the supply of Personal Protective Equipment (PPE) in the state of Amapá, and another regarding the acquisition of 20 million doses of the Covaxin vaccine.
In the first case, the CGU concluded that the company participated in a PPE overpricing scheme under contract with the Amapá Health Department, after investigations by Operation “Virus Infectio II”. The sanction involved a fine of BRL 3,879,251.35, publication of the administrative decision in a widely circulated vehicle, on its website and commercial establishment for 60 days, in addition to the declaration of disqualification to bid or contract with the public authorities. The other company involved in the scheme received a fine in the amount of BRL 22,010.37.
In the second case, the CGU, when judging a request for reconsideration filed by an importer, maintained its declaration of disrepute in a case involving an attempt to supply the Covaxin vaccine to the federal government. The company was held responsible, based on the Anti-Corruption Law, for presenting adulterated documents, including irregular translations, forged power of attorney, false letter of guarantee and invoices in disagreement with the contract. Although this company has alleged the absence of intent and disproportionality of the penalties, the CGU reaffirmed the application of strict liability, clarifying that proof of intent or damage to the treasury is not required for the imposition of sanctions. The request was partially accepted only to reduce the administrative fine to BRL 2,586,167.56 and reduce the deadline for publication of the decision on the company’s premises by 60 days.

July

Regulation of the Use of AI in Public Security

The Ministry of Justice and Public Security published Ordinance No. 961/2025, which establishes guidelines for the use of artificial intelligence (AI) technologies by public security agencies in criminal investigations. The regulation applies to federal, state, district, and municipal institutions that receive funds from the National Public Security Funds (FNSP) and Penitentiary Funds (FPN), as well as to agencies such as CADE and ANPD.
The rule aims to modernize the operations of the security forces without compromising the fundamental rights of citizens. Among its main provisions are the requirement of judicial authorization for access to confidential data and the obligation to discard information related to individuals not involved in the investigation, when technically feasible. The ordinance also imposes limits on the use of remote biometric recognition technologies in real time, prohibiting their application in public spaces, except in exceptional situations, such as the search for missing persons, flagrante delicto of serious crimes, or the fulfillment of judicial warrants.
In addition, it determines that access to AI tools is restricted to previously authorized agents, using strong authentication methods, such as biometrics, digital certificates, or multi-factor authentication. For companies that develop or provide technological solutions to the public sector, the measure reinforces the need for compliance with legal and ethical principles, especially with regard to data protection and system governance.

CGU intensifies the fight against corruption with actions in 7 states and reinforces the accountability of companies for fraud with public funds

The Office of the Comptroller General (CGU) and the Federal Police (PF) have intensified their actions in the fight against corruption in several Brazilian states, focusing on misappropriation of public resources and fraud involving contracts with city halls and federal agencies.
In Bahia, for instance, a scheme involving third sector entities and information technology companies contracted for services in Health was investigated, resulting in fraud in electronic auctions, payment simulations and the blocking of BRL 100 million, in addition to the removal of public agents.
In Mato Grosso do Sul and Rio de Janeiro, evidence of corruption and embezzlement in public contracts in the area of education was identified, with the involvement of civil servants and businessmen. The actions included search and seizure, breaches of confidentiality and the seizure of BRL 510 thousand in cash.
In Rio Grande do Sul, irregularities committed by a company in the food sector were investigated, including sending gifts to public agents in the transport area and tampering with invoices in order to circumvent legal ethical limits. The company was fined BRL 25,176.78 and forced to publish the sanctioning decision.
In Maranhão, a construction company contracted with education resources to renovate municipal schools did not carry out the agreed works. The company was fined BRL 598,485.99, declared unsuitable to contract with the government and had its legal personality disregarded, also reaching its managers.

In another case involving the Ministry of Health, a pharmaceutical supplier won bids for the delivery of high-cost medicines, received the amounts in advance, but did not deliver the products. The loss exceeded BRL16 million, and the company was fined BRL 21,697,740.49, declared disreputable and had its request for reconsideration rejected for lack of proof of the effectiveness of its integrity program.
Finally, in Paraíba, the manipulation of bids and the irregular execution of engineering works funded with federal resources for health, social assistance and education, in collusion with public servants, were found. The company responsible was fined BRL 2,034,970.35, prevented from contracting with the government and had the disregard of its legal personality applied.

August

Operation Hidden Carbon outbreak focuses on tax evasion and money laundering scheme

Operation Hidden Carbon was a major police and tax action in Brazil launched on August 28 that uncovered a sophisticated scheme by the First Capital Command (PCC) to launder money and evade taxes in the fuel sector, also involving the financial market. Led by the Public Prosecutor’s Office of São Paulo (MPSP), through GAECO, and with the support of several institutions, the operation was considered a milestone in institutional cooperation in the fight against organized crime.
The criminal scheme was disguised in the formal economy. The faction used a network of about a thousand gas stations and front companies to move billions of reais. To hide the illicit origin of money from criminal activities, such as drug trafficking, the group carried out complex operations that even involved investment funds and fintechs located in financial centers such as Faria Lima, in São Paulo.
In addition to money laundering, the operation focused on tax fraud and fuel adulteration. The investigations revealed that the criminals even added excess methanol to the gasoline sold, far exceeding the legal limit allowed by the National Petroleum Agency (ANP), which generated exorbitant profits and represented a risk to consumers and vehicles. The Federal Revenue Service identified that the scheme moved around BRL 52 billion between 2020 and 2024.
The action involved the mobilization of approximately 1,400 agents from various security forces and control agencies, such as the Federal Police, Federal Revenue, State Treasury Secretariats and ANP, in at least eight Brazilian states. Hundreds of arrest and search and seizure warrants were carried out, aiming to dismantle the financial and operational structure of the criminal organization at all levels.

Superior Court of Justice decides that LIA and Anti-Corruption Law can be used together

In a decision rendered in a public civil action, the First Panel of the STJ understood that it is possible to apply both the Administrative Improbity Law (Law 8,429/1992) and the Anti-Corruption Law (Law 12,846/2013), as long as they are not used to impose identical sanctions for the same facts.
The trial took place in a case in which a company was accused of having paid bribes to the former governor of Rio de Janeiro, Luiz Fernando Pezão. The Public Prosecutor’s Office requested the blocking of the entity’s assets in the amount of R$ 34 million, based on the two laws.
The company claimed that the joint application would violate the principle of non bis in idem (which prohibits double punishment for the same fact), provided for in the American Convention on Human Rights. But according to the rapporteur of the case, this treaty does not apply to legal entities and, even if applicable, would not prevent the combined use of the rules, as long as there is no repetition of penalties.
The minister pointed out that the risk of double punishment should be assessed only at the end of the process, at the time of sentencing. If the sanctions provided for in one of the laws are applied, the other cannot be used to impose punishments of the same type and unlawful, which reinforces the possibility of simultaneous liability of individuals and legal entities based on different rules, respecting the legal limits to avoid duplicate punishments.

September

New UK rule comes into force that condemns companies for failures in Fraud Prevention

On September 1st, the new corporate crime of Failure to Prevent Fraud (FTPF), introduced by the Economic Crime and Corporate Transparency Act 2023 (ECCTA), came into force in the United Kingdom. The new legislation imposes criminal liability on companies that fail to take reasonable steps to prevent fraud committed by their employees, agents, or third parties acting on their behalf, with the aim of benefiting the organization itself or its customers. It is important to note that the scope of the rule is extraterritorial and may reach foreign companies that have any connection with the United Kingdom, such as meetings, communications, financial gains, or victims in the country.
To comply with the new legal requirement, companies must implement robust fraud prevention policies and procedures, based on six guiding principles defined by the British government: (i) commitment from senior management, which must demonstrate active support for fraud prevention, allocate adequate resources, clearly communicate ethical commitments, and foster an organizational culture focused on integrity; (ii) risk assessment, which requires companies to identify and document the specific risks of fraud in their operations, considering factors such as timeliness, motivation and rationalization; (iii) proportionality of the procedures, which must be clear, practical and adjusted to the complexity and risk profile of the organization; (iv) due diligence, which must be applied to both employees and third parties, with the use of monitoring technologies, background verification, and analysis of organizational culture; (v) communication, training and reporting channels, which must be widely disseminated and incorporated into the company’s routine, with regular training and safe mechanisms for reporting irregularities; and (vi) monitoring and continuous review of procedures, using data, technology and constant learning from internal investigations and complaints received.
As a result, it is essential that companies mobilize their leaders to prioritize the topic, conduct a comprehensive risk assessment, review and adapt their existing compliance policies, and invest in training and technology to ensure compliance. The FTPF represents a significant shift in corporate accountability and requires a proactive and strategic approach to avoid sanctions and protect institutional reputation.

CGU publishes Normative Ordinance on evaluation of integrity program in large-scale contracts

Normative Ordinance No. 226 represents an important milestone in the consolidation of the guidelines provided for in Decree No. 12,304/2024. The decree established new parameters for integrity, governance and compliance programs within the scope of the Public Administration and companies that contract with the government.
The ordinance comes precisely to detail procedures, define objective criteria and guide the practical implementation of these requirements, ensuring greater legal certainty and standardization in the application of the rules. Among the advances brought by the Ordinance, the definition of clear metrics for the evaluation of integrity programs stands out. While the decree established the general principles — such as risk management, transparency, and irregularity prevention mechanisms — the ordinance specifies how these elements must be proven, documented, and analyzed.
It also establishes institutional responsibilities, both for inspection bodies and contracted entities, reinforcing the importance of reporting, auditable evidence, and continuous improvement cycles. The harmonization between the ordinance and Decree 12,304/2024 also strengthens the compliance environment in public procurement. By detailing the integrity check steps, maturity criteria and performance indicators, the standard creates a more objective and comparable process between different organizations. This tends to reduce subjectivities in the evaluation, increase competitiveness in bids, and encourage companies to adopt robust compliance structures, avoiding reputational and operational risks.
Finally, the publication of the Ordinance signals an institutional advance in the public integrity policy. By complementing the decree and offering clear guidelines for its application, the government reinforces its commitment to ethical practices, fraud prevention, and strengthening governance. From this regulation, greater predictability is expected for public and private managers, in addition to a more efficient regulatory environment aligned with the best national and international practices.

Launch of Operation Rejects

On September 17, 2025, the Federal Police launched Operation Rejects, which resulted in the arrest of Caio Mário Trivellato Seabra Filho, then director of the National Mining Agency (ANM). The action, carried out in conjunction with the Office of the Comptroller General of the Union (CGU), focused on the dismantling of a criminal organization accused of corruption, environmental crimes and money laundering.
Trivellato was pointed out as a key player in the scheme, being accused of favoring private interests by manipulating administrative processes within the ANM, including removing from the agenda and asking for views of strategic processes for the investigated group. The investigations revealed that the criminal group operated in the illegal exploration of iron ore in protected areas of Minas Gerais, using fraudulent environmental licenses obtained through the corruption of public servants.
It is estimated that the scheme has moved around BRL 1.5 billion, with profit projections that exceed BRL 18 billion. Trivellato, a lawyer specialized in environmental law, had been appointed to the ANM’s board of directors in 2023 and held a strategic position in the body. According to the Federal Police, he would have received bribes through a law firm and acted deliberately to facilitate the advancement of the interests of the criminal organization.

October

Brazil presents whistleblower protection model as an international reference at the G20

During the 3rd Meeting of the G20 Anti-Corruption Working Group (ACWG), held under the joint presidency of Brazil and South Africa, the Office of the Comptroller General (CGU) presented the Brazilian model of whistleblower protection as an example of practical and ethical implementation of integrity policies.
The side event, entitled “Advancing Whistleblower Protection through Integrity by Design”, brought together international authorities to discuss good practices in the promotion of public integrity, with emphasis on technological and regulatory solutions aimed at protecting those who report irregularities.
Representing the CGU, the head of the Special Advisory for International Affairs, Daniel Mol, presented the case study “Integrity by Design: Practical Implementation of Whistleblower Protection in Brazil”, highlighting the combination of robust legal framework, advanced technology and institutional commitment to ethics.
One of the main points of the exhibition was the Fala.BR platform, a unified national system for receiving and securely handling complaints, which incorporates features such as automatic anonymization, audit trails, and data encryption. Since its implementation, the system has not recorded identity leaks, which has contributed to strengthening society’s trust in control and transparency mechanisms.

Brazilian anti-corruption agencies strengthen international cooperation and institutional integration

During the conference Latin Lawyer & GIR Live: Anti-Corruption & Investigations Brazil, representatives of the Office of the Comptroller General (CGU) and the Office of the Attorney General of the Union (AGU) highlighted the advances and challenges of international and interinstitutional cooperation in the fight against corporate corruption. Marcelo Pontes Vianna, Secretary of Private Integrity of the CGU, and Natália Camba Martins, federal prosecutor of the AGU, stated that, although there are no new cases in progress with US authorities, such as the Department of Justice (DOJ) and the Securities and Exchange Commission (SEC), the dialogue remains active in existing investigations.
According to Vianna, the SEC has contributed with relevant elements to the advancement of a specific CGU case, even in the face of the change in priorities in the US. Martins, in turn, pointed out that cooperation with the DOJ has faced slowness and uncertainties, reflecting a scenario of institutional transition. In this context, Brazilian efforts have expanded to other jurisdictions, such as Singapore, which recently entered into its first leniency agreement based on a bribery case involving a Brazilian state-owned company. Vianna also mentioned strengthening ties with authorities in China and Hong Kong, in response to the slowdown in actions under the FCPA.
Internally, the representatives of the CGU and the AGU emphasized the importance of coordination between public agencies to offer greater predictability and legal certainty to companies involved in accountability processes. The recent memorandum of understanding between CGU, AGU and MPF for joint negotiation of leniency agreements is a concrete example of this integration, which aims to consolidate the so-called one-stop shop for the resolution of corporate corruption cases.
The event reinforced that, even in the face of changes in the international scenario, Brazil remains committed to strengthening its institutional structure to combat corruption, seeking integrated and effective solutions to ensure legal certainty, transparency and integrity in relations between the public and private sectors.

November

European Commission questions change in understanding of “privilege” of in-house lawyers in Europe

The European Commission, through its most recent “Policy Brief” dated November 10, 2025, firmly reaffirmed that legal privilege in the context of antitrust investigations does not extend to communications between companies and their in-house counsel.  According to the document, the protection of confidentiality remains limited to those communications maintained with external, independent and qualified lawyers according to European Union standards. 
This decision puts an end to hopes of a broader expansion of the LPP to companies’ legal departments – an expansion that had been debated in the context of the revision of the EU competition regulation (Regulation 1/2003) and recent consultations with stakeholders.
Proponents of the extension argued that recognizing the privilege of in-house counsel would contribute to the defense of companies’ rights, guarantee the confidentiality of legal communications and reduce costs and bureaucracy. However, the Commission rejected these allegations, stating that there was a risk of abuse, difficulty in defining clear criteria of independence, and a lack of evidence that the extension of the privilege would result in greater compliance with competition laws.
The practical impact of this position of the European Commission is relevant for companies with operations in the European Union. These organizations should be prepared that internal communications with their in-house counsel do not offer the same secrecy protection in the event of antitrust investigations conducted by the Commission. This means that, when it comes to preparing defenses or storing sensitive documents, they may come to rely more on outside lawyers when they want to secure legal privilege.

Launch of Operation Zero Compliance

Operation Compliance Zero was launched by the Federal Police (PF) on November 18, 2025, with the objective of dismantling an alleged scheme of issuance and trading of fake credit securities by financial institutions that are part of the national financial system. Authorities served preventive and temporary arrest warrants and search and seizure warrants in several states — such as Rio de Janeiro, São Paulo, Minas Gerais, Bahia — in addition to the Federal District.
At the center of the investigation is Banco Master, accused of creating non-existent credit portfolios and reselling them to another institution, Banco de Brasília (BRB), simulating accounting backing of about BRL 12.2 billion. The investigation points out that the alleged credit portfolios never actually existed — the “paper” contracts were used to artificially inflate Banco Master’s equity, in order to facilitate asset sale or transfer operations.
The consequences of the Transaction have been immediate and severe: Banco Master was declared in extrajudicial liquidation by the Central Bank of Brazil (BC), which implies the closure of its activities. There was also the arrest of Master’s main controller — Daniel Vorcaro — and other executives, although some were later released, under precautionary measures.
In addition to the financial aspects, Operation Compliance Zero exposes serious regulatory and systemic risks to the national financial system — involving accounting fraud, possible money laundering, and even political influence to conceal irregularities.  The outcome of the investigations and the punishments applied may serve as a milestone in the fight against structured bank fraud, pushing for reforms in governance, internal controls and banking supervision in Brazil.

December

European Union and European Council Reach Provisional Agreement on Minimum Requirements for Combating Corruption

The European Council and the European Parliament have reached a provisional agreement to establish minimum standards for defining and penalizing corruption offenses across Member States. The proposal also includes preventive measures and rules aimed at making investigations and proceedings more effective.

The new law introduces a uniform definition for various acts that will now be considered crimes throughout the European Union. These include: bribery in both public and private sectors, embezzlement, influence peddling, obstruction of justice, illicit enrichment resulting from corruption, concealment, and serious violations related to the unlawful exercise of public office.

Member States will be required to apply equivalent penalties for these crimes. For individuals, sentences range from three to five years of imprisonment, in addition to fines, removal from public office, disqualification from holding public functions, and revocation of licenses. Companies will also be held liable, facing fines of up to 3% to 5% of global turnover or between €24 million and €40 million, depending on the offense.

The legislation defines when a Member State must assume jurisdiction over a crime—generally when it occurs within its territory or involves its nationals. It also provides for preventive measures, such as awareness campaigns, transparency in public administration, the creation of independent bodies for prevention and enforcement, and protection for whistleblowers and cooperating parties.

The directive will replace two previous instruments: a 2003 law on corruption in the private sector and a 1997 convention on corruption involving EU officials. The agreement must still be formally confirmed by the Council and Parliament before adoption.

ZTE in Negotiations with the DOJ over FCPA Resolution

ZTE, one of China’s largest telecommunications companies, has confirmed that it is in discussions with the U.S. Department of Justice (DOJ) to resolve allegations of violations of the Foreign Corrupt Practices Act (FCPA). The information was disclosed in an official statement following reports indicating that the settlement could exceed US$1 billion, potentially reaching US$2 billion, to close bribery allegations involving contracts in South America and other regions. This substantial amount signals a serious resumption of FCPA enforcement by the DOJ after a period of investigative pause and reinforces the message that corrupt practices remain a top priority for U.S. authorities.

In 2017, the company paid US$1.19 billion to settle accusations of violating U.S. sanctions and export controls, admitting to conspiring to supply technology to countries such as Iran and North Korea. More recently, in November 2025, the Federal Communications Commission (FCC) announced restrictions on the sale and import of ZTE equipment due to national security concerns. This history heightens the company’s reputational and financial risks, making the current negotiations even more complex.

In its statement, ZTE reaffirmed its zero-tolerance policy toward corruption and pledged to strengthen its compliance system by building a framework considered industry-leading. The company also declared that it will defend its rights through legal means but acknowledged the need to reinforce internal controls and demonstrate cooperation with authorities.

The ZTE case underscores that compliance is an essential pillar for corporate sustainability. Companies operating internationally must adopt robust programs aligned with global best practices to prevent legal, financial, and reputational risks. In an environment of increasingly stringent enforcement, corporate integrity is no longer optional—it has become an indispensable requirement for survival and competitiveness in the global market.

CGU Observatory 2025 (as of 12/05)

In 2025, the Office of the Comptroller General (CGU) initiated 237 administrative accountability proceedings, of which 14 have already been concluded, resulting in 24 sanctions imposed. The total amount of fines reached BRL 5,157,422.00.

Subject Matter of the Facts

• Fraud in public procurement procedures of the national administration;

• Payment or offer, directly or indirectly, of undue advantage to a national public official or a related third party;

• Fraud in administrative contracts executed with the national public administration;

• Unjustified breach of clauses in contracts executed with the public administration;

• Improper conduct;

• Concealed use of an intermediary to obtain undue advantage from the national public administration;

• Irregularities or fraud in bidding processes or contracts;

• Financing, funding, sponsoring, or subsidizing unlawful acts as defined under the Anti-Corruption Law (Law No. 12,846/2013);
  
• Obstructing or interfering with investigative or oversight activities of national public bodies or officials.
  
• Self-dealing or granting undue advantage to third parties.