Compliance, Investigations and White-Collar

Compliance, Investigations and White-Collar

Act # 12,846/2013, known as the “Anti-Corruption Act”, set up a new scenario with regard to the fight against corruption in Brazil. The Act states that legal entities involved in corrupt practices shall be held responsible both in administrative and civil spheres, being subject to penalties such as fines of up to 20% of the entity’s annual gross revenue, as well as to the obligation to repair the damage caused.

Azevedo Sette Advogados has a team dedicated to assistance on corruption prevention, detection and response strategy, taking into account not only the Brazilian Clean Company Act, but also other Brazilian norms (such as the Money Laundering Act, the Administrative Misconduct Act, among others), International Treaties (within the ambit of the United Nations, OCDE, OAS and EU) and foreign legislation, such as the Foreign Corrupt Practices Act (FCPA), from the United States and the UK Bribery Act (UKBA), of the United Kingdom.

Legal advice in the Anti-Corruption, Compliance and Corporate Integrity area of Azevedo Sette Advogados covers:

  • Assessment of the specific risks of the legal entity (risk assessment);
  • Creation, development and review of compliance programs;
  • Drawing up, review and implementation of codes of ethics and conduct;
  • Implementation and improvement of internal controls;
  • Development and improvement of whistleblowing channels;
  • Lectures and training for employees;
  • Assistance in internal disciplinary procedures;
  • Due diligence: internal, third-party and M&A anti-corruption due diligence;
  • Formulation of clauses and review of contracts according to Anti-Corruption laws and regulations;
  • Advice on and representation in leniency agreements with authorities;
  • Representation in administrative and court proceedings.