Corporate Investigations Newsletter – March 2026

The Corporate Investigations Newsletter aims to provide information on the main media news, trends, cases, and legislation concerning compliance, white-collar crime, competition and international trade matters in Brazil and abroad. This newsletter is for informative purposes only, and should not be used for decision making. Specific legal counseling may be provided by our legal team.

Enjoy reading!

Compliance and Investigations, White-Collar Crime, Competition, and International Trade and Customs teams

CGU publishes best practices for Brazilian export companies and strengthens international cooperation against corruption

On February 26, 2026, the Brazilian Office of the Comptroller-General (CGU) released the Guide to Good Integrity Practices for Brazilian Export Companies, developed in partnership with the Brazilian Trade and Investment Promotion Agency (ApexBrasil). The launch took place during the seminar “Integrity Beyond Borders: Combating Corruption in International Commercial Transactions,” held in Brasília, which brought together representatives from the public sector, companies with international operations, and compliance and integrity professionals.

The guide aims to advise exporting companies on the importance of developing, implementing, and monitoring integrity programs, taking into account the specific risks associated with international operations, such as cross-border bribery and money laundering. Among other matters, the guide addresses Law No. 12,846/2013 (Clean Company Act) and Law No. 14,133/2021 (Public Bidding and Administrative Contracts Law). It provides examples of red flags, preventive measures, and guidance on implementing structured responses when irregularities are identified.

For more information, please access the CGU’s full report.

DOJ announces new corporate enforcement policy applicable to all criminal cases

On March 10, 2026, the U.S. Department of Justice (DOJ) released its first corporate enforcement policy to be applied uniformly across all criminal cases involving companies, except for antitrust offenses.

The new Department-wide Corporate Enforcement Policy aims to increase certainty, consistency, and transparency in the DOJ’s enforcement of corporate crimes.

The policy establishes tangible benefits for companies that self-disclose misconduct, cooperate with investigations, and implement appropriate and timely remedies. The DOJ also stated that it will decline criminal prosecution for companies that meet these requirements, provided there are no specific aggravating factors. Additionally, the policy replaces and consolidates previous guidelines adopted by specific divisions of the DOJ or by local prosecutors’ offices and will apply comprehensively to corporate criminal cases.

For more information, please access the DOJ’s full release.

CGU proposes regulation of integrity program evaluations in state and municipal public procurement

On March 17, 2026, the Brazilian Office of the Comptroller-General (CGU), through the Secretariat for Private Integrity (Sipri), proposed a regulation to guide states and municipalities in evaluating integrity programs associated with public procurement. The initiative is in the final report of the working group established under the National Network for the Promotion of Private Integrity.

The proposal provides for guidelines, technical criteria, and risk mapping to support the implementation of Law No. 14,133/2021 (Public Bidding and Administrative Contracts Law). The proposal aims to standardize the application of integrity requirements in subnational public procurement. It provides for the use of the Integrity Program Assessment and Monitoring System (Sampi), developed by the CGU, as a tool to support evaluations conducted by states and municipalities.

For more information, please access the CGU’s full article.

CGU and Federal Police launch new phase of Operation Sem Desconto

In March 2026, the Brazilian Office of the Comptroller-General (CGU) and the Federal Police (PF) launched a new phase of Operation “No Discount” (Operação Sem Desconto), which is investigating a nationwide scheme involving unauthorized deductions from the benefits of retirees and pensioners.

In this phase, authorities executed 19 search and seizure warrants, 2 arrest warrants, and additional precautionary measures issued by Brazil’s Federal Supreme Court in the states of Ceará and the Federal District.

The investigation is looking into crimes such as entering false data into computer systems, social security fraud, criminal conspiracy, and money laundering. The investigations originated from audits conducted by the CGU and seek to determine the role of entities and individuals involved in the improper deductions.

For more information, see the CGU’s full article.

STJ suspends pretrial detention pending expert examination of digital evidence

The Sixth Panel of Brazil’s Superior Court of Justice (STJ) held that an expert examination is essential to admit digital evidence in pretrial detention decisions when there is reasonable doubt regarding the integrity and authenticity of such evidence.

On that basis, the panel replaced the defendant’s pretrial detention with alternative precautionary measures until such expert examination is concluded.

According to the rapporteur, Justice Carlos Pires Brandão, digital evidence has features that allow for imperceptible alterations, thus requiring heightened rigor in its collection and preservation.

In the case at issue, the defense argued that the police obtained the screenshots of WhatsApp conversations – allegedly the only evidence against the defendant – through direct access to the device, without any record of the technical procedures, and that CCTV footage was also introduced as evidence without expert examination.

Brandão emphasized that it is the State’s burden to demonstrate the integrity and authenticity of the digital evidence, and that the lack of technical documentation reduces the reliability of the material.

Accordingly, the expert examination is not intended to invalidate the evidence, but rather to remedy the technical deficit and ensure effective adversarial proceedings between the parties.

As for the CCTV images, the reporting justice noted that when such images are extracted directly from the recording system, and their origin is identified, they enter the record as documents and do not require expert examination.

In that scenario, the defense may challenge cuts or inconsistencies, but forensic rigor is essential for data obtained from electronic devices.

Given the need to confirm the authenticity of the digital elements used in the investigation, the STJ found that, although the evidence did not eliminate probable cause, the uncertainties warranted replacing pretrial detention with alternative precautionary measures until the expert examination is completed.

See the full STJ report in Portuguese.

House approves bill increasing sentences for property crimes

Brazil’s Chamber of Deputies (House of Representatives) approved a bill that increases sentences for various property crimes, including theft, robbery, receiving stolen property, and robbery resulting in death (latrocínio).

According to the rapporteur, Congressman Alfredo Gaspar, the approved wording – a substitute for Bill No. 3,780/23 – seeks to restore tougher penalties after Senate amendments had relaxed original punishments.

Below are the main changes introduced by the bill:

Theft (furto):

• Base sentence: increased from 1–4 years to 1–6 years of imprisonment; increased by one-half when the offense is committed at night.
• Sentence of 4–10 years in cases involving: electronic fraud; vehicles taken to other states or abroad; cattle and other livestock; electronic devices.
• New aggravating circumstance: theft of pets.

Robbery (roubo):

• General sentence: increased from 4–10 years to 6–10 years of imprisonment.
• Increased penalties in cases involving electronic devices or the use of a firearm.

Serious bodily harm (lesão corporal grave):

• Sentence increased to 16–24 years of imprisonment.

Robbery resulting in death (latrocínio):

• Minimum sentence set at 24 years of imprisonment.

Receiving stolen property (receptação):

• General sentence: increased from 1–4 years to 2–6 years of imprisonment.
• Receiving livestock, meat, or pets: 3–8 years of imprisonment.

Interruption of telecommunications services:

• Sentence becomes 2–4 years of imprisonment.
• Sentence doubled in cases of public calamity or destruction of equipment.

Swindling (estelionato):

• Criminalization of the assignment of a “mule” account used to move funds from illicit activities.
• Creation of a qualified fraud by electronic deception crime, with a sentence of 4–8 years, covering schemes involving device cloning or digital applications.
• Removal of the requirement for complaints filed by victims to initiate prosecution, allowing the Public Prosecutor’s Office to file charges regardless of the victim’s complaint (currently, this occurs only when the crimes are committed against the government or involve vulnerable victims).

The bill will now move forward for presidential approval.

See the Migalhas article on the matter in Portuguese.

STF will move the trial on internet user data access rules to an in-person format

Brazil’s Federal Supreme Court (STF) will review, in an in-person plenary session, the case addressing rules for access to internet user data that enables identification, such as information associated with IP addresses.

The judgment, which had been underway in the virtual plenary, will be restarted after Justice Flávio Dino requested that it be removed for in-person consideration.

The dispute arises within the context of direct action for the declaration of constitutionality (ADC) 91, filed by Abrint (the Brazilian Association of Internet and Telecommunications Providers). ADC 91 seeks recognition of the constitutionality of Article 10, paragraph 1 of Brazil’s Internet Civil Rights Framework (Marco Civil da Internet), which conditions access to connection logs and application access records on prior judicial authorization.

In his vote in the digital session, the rapporteur, Justice Cristiano Zanin, upheld the constitutionality of the proposition and proposed a conforming interpretation.

He argued that authorities may directly request only basic subscriber registration data (e.g., name, address, parentage). Still, access to traffic data – including connection logs and application access logs – requires judicial authorization, given that such data may reveal users’ habits, routines, and relationship networks.

Zanin also noted that identifying a user by an IP address requires correlating subscriber and traffic data, which should likewise be subject to judicial authorization.

He nevertheless admitted the possibility of an exception in situations of extreme urgency – such as kidnappings, terrorist attacks, or ongoing cybercrimes – allowing an immediate request, subject to subsequent judicial review.

In a concurring opinion, Justice Dias Toffoli agreed with the reporting justice on the constitutionality but disagreed with allowing direct access in exceptional cases. In his view, admitting exceptions without a specific legal basis may violate personal data protection rights and create risks of abuse; any access without a court order should be defined by statute and comply with proportionality criteria.

The justices also discussed prospective-only application (modulation of effects). Zanin and Toffoli proposed that any decision apply only going forward to preserve investigations already carried out.

With the request for in-person review, the judgment will restart in the physical plenary, with no date set yet.

See the full Migalhas report in Portuguese.

New law expands tools to combat organized crime and strengthens precautionary measures involving legal entities

On March 24, 2026, Brazil enacted Law No. 15,358/2026, which establishes the Legal Framework for Combating Organized Crime.

The new law aims to establish mechanisms to combat ultra-violent criminal organizations, paramilitary groups, and private militias. It establishes punishments for conduct aimed at territorial control and at intimidating the community, as well as public and private institutions.

The new law also amends multiple statutes, including the Criminal Code, the Code of Criminal Procedure, the Heinous Crimes Law, the Criminal Enforcement Law, the Drug Law, the Disarmament Statute, the Money Laundering Law, and the Electoral Code.

Among the key developments, the law strengthens the system of provisional measures, allowing judges, even at the investigative stage, to order seizure, attachment, and blocking of assets, including digital assets, equity interests, investment funds, corporate participations, and assets held abroad.

The law also authorizes the suspension of economic activities that may be used to conceal or disguise illicit assets. It allows the blocking of access to payment systems and digital platforms, while requiring immediate notice to authorities such as the Council for Financial Activities Control (Coaf), the Central Bank of Brazil, the Brazilian Securities Exchange Commission (CVM), the Superintendence of Private Insurance (Susep), and the Brazilian Federal Revenue Service.

The investigated or accused party is given ten days to prove the lawful origin of seized assets, and failing to do so will result in extraordinary forfeiture.

The law also provides for court-ordered intervention in companies that benefit from illicit activities carried out by criminal factions or militias, including the immediate removal of partners or shareholders and appointment of a court administrator for up to six months, which can be renewed.

During the intervention, the administrator may suspend suspicious contracts, terminate ties with investigated parties, conduct financial audits, propose a restructuring or liquidation plan, and deposit amounts into a judicial account.

The legal entity may also have its public-sector contracts suspended. It will be barred from entering into new public contracts, participating in bids, or receiving tax incentives for the duration of the measure.

The law further amends Law No. 14,790 (fixed-odds betting), adding new administrative sanction grounds for agents that maintain commercial relationships with unauthorized betting operators, fail to implement internal controls, or run advertising associated with such operators.

The new law also introduces Article 24-A, requiring financial and payment institutions to integrate interoperable systems for sharing information on electronic fraud, including prevention, detection, and response mechanisms such as the blocking and enhanced review of suspicious transactions.

See the full law in Portuguese.

STJ acquits defendants of tax evasion due to a lack of proof of probable cause

The STJ acquitted two defendants convicted of tax evasion, finding a lack of proof of probable cause of the offense in Special Interlocutory Appeal 3,111,920/SC.

The rapporteur, Justice Ribeiro Dantas, stated that the conviction was based solely on an administrative conclusion that the target company failed, in tax proceedings, to prove the transactions that generated disallowed ICMS (tax on the circulation of goods) credits, which is not enough to support a criminal conviction.

The case began after the cancellation of state taxpayer registrations of supplier companies, leading the tax authority to presume that the purchases had not occurred.

In the criminal proceeding, however, no evidence of the alleged fraud was discovered: there was no demonstration that invoices were false, that the transactions did not occur, or that there was collusion between the defendants and suppliers; nor were there investigative steps capable of confirming a simulated transaction scheme. In other words, the prosecution essentially reproduced the administrative conclusion.

According to the reporting justice, although the taxpayer bears the burden of proving the legitimacy of transactions in the tax sphere, that burden does not carry over into criminal proceedings, in which the burden of proof rests exclusively with the prosecution regarding probable cause.

The mere insufficiency of documentation in tax proceedings cannot replace affirmative proof of fraud; otherwise, Articles 155 and 386, paragraph 2 of the Code of Criminal Procedure would be violated.

As the prosecution did not submit evidence of the alleged simulated transactions, the STJ granted the special appeal and fully acquitted the defendants.

The decision established the precedent that a criminal conviction for tax evasion requires proof of facts demonstrating the conduct charged as a crime.

See the full STJ ruling in Portuguese.

CADE study reveals high concentration in the retail fuel resale market

On March 4, 2026, the Department of Economic Studies (DEE) of the Administrative Council for Economic Defense (CADE) published the Working Paper “Concentration in the Retail Resale of Liquid Fuels: A Municipal-Level Analysis Based on Corporate Networks (2025).” The study aimed to measure concentration levels of liquid fuels in retail markets across Brazilian municipalities.

The study analyzed the markets for regular gasoline (gasoline C), hydrated ethanol, diesel B S10, and diesel B S500, based on cross-checking data from the National Agency of Petroleum, Natural Gas and Biofuels (ANP) and the Federal Revenue Service, as of August 2025. The methodology applied network theory to identify and group fuel stations with common shareholders, thereby revealing ownership structures that are not easily visible to consumers and may reduce effective competition.

The results indicate that more than half of Brazilian municipalities had markets classified as highly concentrated (Herfindahl–Hirschman Index above 2,500), especially in smaller municipalities.

Percentage of highly concentrated markets by fuel sold:

• 79% for regular gasoline (gasoline C)
• 85% for hydrated ethanol
• 59% for diesel B S10
• 02% for diesel B S500

According to the DEE, this pattern is influenced by the limited scale of local demand, regulatory and economic barriers to entry, the presence of regional or local groups, and the high degree of corporate interdependence among stations.

The DEE recommended continuous monitoring of the sector – both merger control filings and anticompetitive conduct – and highlighted the need to increase transparency around stations’ ownership structures to reduce information asymmetries.

The study does have limitations, however, as using the number of stations as a proxy for market share due to the lack of public data on sales volumes may cause isolated distortions in the measurement of concentration.

See the full study in Portuguese.

CADE opens public consultation on the Guidelines on Collaboration Between Competitors

On March 18, 2026, CADE opened a public consultation to develop the Guidelines on Collaboration Between Competitors, which consolidates CADE’s understanding of cooperative arrangements between competing companies under Law No. 12,529/2011 (Brazilian Competition Law).

The draft recognizes that collaborations can be legitimate and pro-competitive. Still, it stresses that certain arrangements are unlawful by purpose (such as price fixing, market allocation, bid rigging, and no-poach agreements) or may be unlawful due to anticompetitive effects they may cause, depending on their design and implementation. The draft adopts a broad concept of cooperation, encompassing formal contracts and informal interactions, including through third parties, and a practical notion of what constitutes competitors.

In addition, the document notes that associative agreements may be subject to prior review by CADE and may not be implemented before approval. It also limits the exchange of competitively sensitive information to what is strictly necessary. The regulation requires prior notification when the agreement:

• has a term equal to or longer than two years;
• involves a joint undertaking, with sharing of risks and results; and
• is entered into between competitors in the market targeted by the agreement.

The draft guide also addresses specific types of competitor collaboration:

• Associations, trade unions, and industry bodies: are permitted for institutional representation and dissemination of best practices. The exchange of sensitive information, such as prices, volumes, and strategies, is prohibited.
• Buying groups: are acceptable to generate efficiencies, provided they do not involve monopsony power, exclusivities, or the circulation of sensitive data.
• Joint production, sales, distribution, or logistics: it is compatible when ancillary and aimed at cost reduction, without unifying commercial decision-making.
• Sharing of assets, infrastructure, or technology: it is allowed for spreading costs or expanding access, provided it does not restrict competitors or standardize strategies.
• Industry studies, market intelligence, and benchmarking: it is legitimate, provided that data are aggregated, anonymized, and time-lagged. Individualized strategic information is prohibited.
• Data sharing: it is permitted, provided that sensitivity is adequately mitigated. It is riskier in concentrated markets.
• Network infrastructure sharing: it is compatible when it expands efficiency and coverage, provided it preserves competitive autonomy.
• Innovation and R&D: it is permitted for sharing technological risk, provided it does not eliminate rivalry or alternative projects.
• Standardization and interoperability: it is legitimate, provided they are pursued openly and on non-discriminatory basis, without aligning competitive variables.
• Sustainability and environmental initiatives: are acceptable when proportionate and focused on verifiable environmental benefits, without substituting competition.
• Crises and emergencies: emergency collaborations are admissible if strictly temporary, proportionate to the event, and limited in scope.

The Guidelines on Collaboration Between Competitors also emphasizes the sharing of competitively sensitive information. It provides best practices to mitigate risks, such as aggregation and anonymization, temporal delays, the use of independent third parties, clean teams, and antitrust protocols.

Importantly, the guidelines do not bind CADE’s internal bodies and do not exhaustively analyze specific cases. Companies should still seek specialized legal advice for each arrangement.

The deadline to submit contributions through the Brasil Participativo platform runs until May 4, 2026.

See the public consultation in full in Portuguese.

SRE begins competition review of five regulations under the 2nd PARC Cycle

On March 26, 2026, the Secretariat for Economic Reforms (SRE) announced the start of the review phase and the proposal of revisions under the 2nd Cycle of the Regulatory and Competition Assessment Procedure (PARC), based on 35 contributions received between January 5 and February 28, 2026, via the Brasil Participativo platform.

The following sectors were brought up the most:

• Transportation (31.4%)
• Energy (14.3%)
• Healthcare, financial markets, and telecommunications (8.6% each)

Based on the submissions received, the SRE selected five regulations for in-depth assessment:

The SRE will begin institutional discussions with the competent regulators to understand the rationale for the regulations and assess necessary adjustments from a competition perspective. The SRE will also hear from economic agents and representative entities.

Interested parties may engage with the SRE and submit studies and contributions. At this stage, the consultation phase is expected to last up to two months, with completion in September 2026.

See the full note in Portuguese.

CADE implements artificial intelligence project to modernize competition review

On March 19, 2026, CADE began implementing the Economic Defense with Artificial Intelligence project (Defesa Econômica com Inteligência Artificial – DEIA), a strategic initiative to incorporate AI solutions into CADE’s workflows. The project is part of CADE’s Digital Transformation Plan and is funded with resources from the Diffuse Rights Defense Fund.

The DEIA project establishes the use of AI assistance for case triage, document review, pattern identification, and case development. The initiative includes applications for core authority routines, such as merger review, detection of anticompetitive conduct, and integration of functionalities into the SEI system, including automatic document classification, draft suggestions, content extraction and summarization, and predictive analyses of deadlines and risks.

According to CADE’s Administration and Planning Directorate (DAP), AI will complement technical work under human supervision, in line with the principles of transparency and accountability, with due attention to data governance and information security. The initiative includes training for public servants and aims to improve efficiency, reduce processing times, and improve decision-making, ultimately solidifying CADE’s role in fostering more competitive, efficient, and innovative markets.

See CADE’s full release in Portuguese.

CADE upholds interim measures involving WhatsApp and Itaú

In ruling sessions held in March 2026, CADE’s Tribunal decided to uphold interim measures imposed by the General Superintendence in voluntary appeals filed by WhatsApp/Facebook Brasil (Meta) and Itaú Unibanco.

• At its March 4, 2026 ruling session, CADE’s Tribunal unanimously upheld the interim measure that suspended the application of the new WhatsApp Business terms of use, which have been under investigation since January 2026 following complaints by Luzia and Zapia. According to the reporting commissioner, Carlos Jacques, the announced changes could restrict developers’ and AI providers’ access to the platform, creating a risk of discrimination and market foreclosure, particularly if Meta AI is favored. In this landscape, the Tribunal decided to maintain the interim measure until a final decision on the merits is reached.
• At its March 18, 2026 ruling session, the Tribunal unanimously upheld the interim measure applied to Itaú Unibanco in an investigation into potential anticompetitive conduct in the payments and digital wallets markets. The measure requires Itaú to refrain from denying cash-in transactions without a legitimate rationale. This payment modality allows a user to add funds to their digital wallet using a credit card, which can later be used for payments, transfers, or other transactions. In addition, this model requires clear, objective rationales for exceptional transaction denials. According to the reporting commissioner and CADE’s President, Gustavo Augusto, the conduct under investigation may inhibit fintech activity and innovation in the sector, creating barriers to competition. Accordingly, the extension of the measure to other issuers with a dominant position is accepted in principle.

Failure to comply with the measures subjects the companies to a fine of BRL 250,000 per day for WhatsApp and per event for Itaú.

See CADE’s reports in full:

Cade mantém medida preventiva aplicada ao Itaú

Tribunal do Cade mantém medida preventiva sobre novos termos de uso do WhatsApp.

SECEX initiates new antidumping investigations and a public interest review

In March 2026, the Secretariat of Foreign Trade (“SECEX”) initiated three sunset reviews of antidumping measures, one original antidumping investigation, and a public interest review of a trade remedy measure, as follows:

• Sunset review of the anti-dumping duty imposed on Brazilian imports of butyl acrylate from the United States
  • Opening: SECEX Circular Letter No. 17, of March 09, 2026
  • Product: Butyl acrylate, commonly classified under subheading 2916.12.30 of the MERCOSUR Common Nomenclature (“NCM”).
• Investigation into dumping and injury regarding Brazilian imports of graphite electrodes from China and India
  • Opening: SECEX Circular Letter No. 18, of March 11, 2026
  • Product: Graphite electrodes, commonly classified under NCM subheading 8545.11.00.
• Sunset review of the anti-dumping duty imposed on Brazilian imports of truck tires from China, Korea, Japan, and Thailand
  • Opening: SECEX Circular Letter No. 20, of March 19, 2026
  • Product: Radial construction tires with rim sizes of 20“, 22”, and 22.5″, for use on buses or trucks (truck tires), commonly classified under NCM subheading 4011.20.90.
• Public interest review regarding the anti-dumping duty imposed on Brazilian imports of titanium dioxide pigments from China
  • Opening: SECEX Circular Letter No. 21, of March 26, 2026
  • Product: Rutile-type titanium dioxide pigments, commonly classified under NCM heading 3206.11.10.
• Sunset review of the anti-dumping duty imposed on Brazilian imports of adipic acid from Germany, China, the United States, France, and Italy
  • Opening: SECEX Circular Letter No. 24, of March 30, 2026
  • Product: Adipic acid, commonly classified under NCM heading 2917.12.10.

Brazil’s MDIC launches public consultations on MERCOSUR agreement negotiations with Vietnam and South Korea

On April 1, 2026, Brazil’s Ministry of Development, Industry, Trade, and Services (“MDIC”) launched, through SECEX, public consultations to gather opinions regarding MERCOSUR’s trade negotiations with Vietnam and the Republic of Korea, allowing companies, industry associations, academia, and other interested parties to submit comments within 45 days, with a view to informing the definition of Brazil’s negotiating position in talks conducted jointly with the other countries of the bloc. Comments must be submitted through the public consultation portal of the Integrated Foreign Trade System (“SISCOMEX”).

Below, we highlight the main features of the public consultations:

• Republic of Korea: Discussions on a broad-based Free Trade Agreement (“FTA”) covering goods, services, investment, rules of origin, sanitary and phytosanitary measures, technical barriers to trade, and digital trade.

Access the full text of Circular No. 25, dated March 31, 2026.

• Vietnam: Negotiation of a Preferential Trade Agreement (“PTA”), with a more limited scope, aimed at the gradual reduction of tariffs in selected sectors and the facilitation of trade, in accordance with the mandate approved by the Strategic Council of the Foreign Trade Chamber (“CAMEX”) in September 2025.

Access the full text of Circular No. 26, dated March 31, 2026.

The contributions submitted to the MDIC will help identify opportunities and challenges for different sectors of the Brazilian economy and guide Brazil’s approach to these negotiations within the MERCOSUR framework.

Brazil regulates bilateral safeguards in trade agreements

On March 04, 2026, Decree No. 12,866 was enacted, regulating the procedures for investigating and applying bilateral safeguards provided for in trade agreements, establishing the conditions for adopting such measures in the face of sudden increases in imports resulting from negotiated tariff reductions. This reflects the current expansion of Brazil’s network of trade agreements, which, in 2023, began to include negotiations with Singapore, the European Free Trade Association (“EFTA”), and, more recently, the execution of the FTA between MERCOSUR and the European Union (“EU”).

The decree provides for instruments such as the temporary suspension of the tariff elimination schedule, the reinstatement of previous tariffs, or the adoption of tariff quotas, following an investigation conducted by SECEX, the MDIC, and a subsequent final decision by CAMEX. The text ensures the participation of interested parties, as well as the possibility of initiating ex officio investigations in exceptional situations.

Additionally, on March 30, 2026, SECEX launched, through Circular No. 23 of March 26, 2026, a public consultation to gather comments to support the drafting of an ordinance on the topic. Contributions must be submitted by April 28, 2026, on the Brasil Participativo portal.

Access the full text of Decree No. 12,866.

WTO: New notification of safeguard investigations issued

Throughout January, Canada, Russia, and the EU notified the World Trade Organization (WTO) of the launch of safeguard investigations.

Canada initiated an investigation into certain vegetable goods, and Russia into imports of tinplate. Meanwhile, the EU initiated an investigation into grain-oriented electrical steel.

Access the notification issued by Canada.

Access the notification issued by Russia.

Access the notification issued by the EU.