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Corporate Investigations Newsletter – July 2026

August 11th, 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

U.S. sanctions Brazilian individuals and companies for alleged ties to the PCC

The U.S. government announced the first round of sanctions following the designation of Primeiro Comando da Capital (PCC) as an international terrorist organization.

The measure adopted by the U.S. Department of the Treasury targets Brazilians Victor Henrique de Oliveira Shimada and Stella Stefanie Nunes Henrique de Oliveira, as well as the companies Victory Trading Intermediação de Negócios Cobranças e Tecnologia Ltda., Pixwave Soluções de Pagamentos Ltda., Wave Construções Inteligentes Ltda., and the Portuguese company Avenidas Flutuantes Unipessoal Lda. According to U.S. authorities, those sanctioned are part of an international network that launders money to the PCC.

Investigations conducted in Florida indicate that the structure used companies to move funds linked to the criminal organization and to facilitate financial transactions between Brazil and the United States.

In an official statement, the Treasury Department claimed the PCC poses a significant threat to U.S. national security and uses the U.S. financial system for money laundering. The sanctions resulted in the freezing of the assets and interests of affected individuals and companies under U.S. jurisdiction.

See more details (PT-BR): EUA anunciam sanções contra duas pessoas e três empresas brasileiras por suposta ligação com o PCC.

CGU recognizes 128 companies for excellence in integrity and corporate governance

The Brazilian Office of the Comptroller-General (CGU) has set a new record for the number of organizations awarded under the Empresa Pró-Ética program: 128 companies were recognized for implementing integrity programs and corporate governance practices. The ceremony held in Brasília on Business Integrity Day assembled representatives from the public sector, the private sector, academia, and partner institutions.

The 2025-2026 edition of the program introduced significant innovations. For the first time, recognized companies were exempted from a new assessment of their integrity programs for large-scale Federal Government procurement procedures. This highlights the importance of this pro-ethics program in publicly recognizing and incentivizing the continuous improvement of compliance, governance, and corruption-prevention practices.

During the event, the CGU also launched the Clean Company Act and Private Integrity in Data Panel, presented the updated Anti-Corruption Leniency Program Guide and the third edition of the Private Entity Accountability Manual, and announced a public consultation to regulate the piercing of the corporate veil in administrative liability proceedings.

Empresa Pró-Ética recognizes organizations that implement measures to prevent, detect, and address corruption and fraud, ultimately fostering integrity in relationships between the public and private sectors.

See more details (PT-BR): CGU reconhece 128 empresas por excelência em integridade e governança corporativa.

Federal Supreme Court strengthens transparency and reporting requirements for parliamentary amendments

Federal Supreme Court Justice Flávio Dino has ordered the notification of 6 states and 53 municipalities with outstanding issues in the reporting of funds received through parliamentary amendments. The decision reinforces the requirement to submit work plans and management reports via the Transferegov.br system and intensifies scrutiny regarding compliance with transparency and traceability obligations for these funds.

The measure focuses on companies that benefited from the Emergency Program for the Recovery of the Events Sector (Perse) and received funds from “Pix amendments” between 2020 and 2024. According to a CNN Brasil report, failure to provide the required information could result in a daily fine of 1% of the amount received through these amendments until they comply with the ruling.

The initiative is part of a series of measures led by Flávio Dino to better oversee the implementation of parliamentary amendments and to ensure greater transparency in identifying beneficiaries and allocating public funds. These requirements stem from negotiations among Brazil’s three branches of government and are part of efforts to strengthen the accountability and traceability of federal funds.

See more details (PT-BR): read the full CNN Brasil report.

Brazil’s Federal Police indicts 48 individuals in investigation of unauthorized deductions from social security benefits

The Brazilian Federal Police has indicted 48 individuals following the first phase of Operation No Deduction (Operação Sem Desconto), which is investigating a scheme of unauthorized deductions from National Social Security Institute (INSS) pensions and benefits. Investigated parties include former INSS president Alessandro Stefanutto; former attorney-general Virgílio de Oliveira Filho; former benefits director André Fidelis; lobbyist Antônio Carlos Camilo Antunes, known as “Careca do INSS”; and CONAFER president Carlos Roberto Ferreira Lopes. These suspects could face charges for criminal organization, money laundering, passive corruption, and active corruption.

The scheme deducted monthly amounts from the pension and retirement benefits as membership fees for retiree associations, although they had neither joined nor authorized such charges. The Federal Police are investigating the roles of associations and intermediaries in these improper deductions, which could amount to roughly BRL 6.3 billion.

The investigation report was submitted to Supreme Court Justice André Mendonça and will be reviewed by the Office of the Prosecutor-General (PGR) to assess next steps.

See more details (PT-BR): G1 news report.

STJ rules that machinery used in environmental crimes can be seized regardless of the owner’s bad faith

The Second Panel of Brazil’s Superior Court of Justice (STJ) ruled by majority that the seizure and forfeiture of machinery used in environmental violations do not hinge on proving the owner’s bad faith; proof of the offense alone is sufficient.

The case involved a tractor used to clear an environmental preservation area. The owner claimed to have acted in good faith when renting the vehicle to third parties, but the STJ, based on Brazil’s Environmental Crimes Law, held that the seizure and potential forfeiture of the asset do not depend on an analysis of the owner’s conduct and stem directly from the use of the tractor in the environmental violation. The prevailing opinion is that requiring proof of the owner’s bad faith would impose a requirement not contemplated in the legislation and jeopardize the effectiveness of environmental protection.

Justice Maria Thereza de Assis Moura emphasized that any owner who provides an asset for economic purposes automatically assumes the inherent risks of its use by third parties. As a result, the definitive loss of such asset is a direct consequence of the environmental crime. According to the rapporteur, this interpretation broadens the preventive effect of the environmental law and ensures the enforcement of the in dubio pro natura principle, that is, in favor of environmental protection.

See more details: ruling in full.

São Paulo’s Court of Justice forms specialized unit to combat organized crime and money laundering

The Court of Justice of the State of São Paulo (TJSP) has established new state courts specialized in criminal organizations and the laundering of assets, rights, and funds. The initiative is part of a national strategy coordinated by the National Council of Justice (CNJ) to strengthen the Judiciary Branch in combating organized crime and financial crimes.

These specialized units will prosecute and try cases involving criminal organizations, money laundering, tax and economic crimes, and violations related to public tenders and administrative contracts. The new framework also provides for oversight by a State Court of Guarantees, which specializes in investigating these cases.

The authorities claim the measure will further specialize criminal jurisdiction, standardize judicial decisions, and optimize the processing of highly complex investigations and criminal proceedings.

Justice Edson Fachin emphasized that organized crime poses an expanding institutional challenge, particularly given its use of corporate structures, complex financial operations, and money-laundering mechanisms to conceal illicit assets. The justice also emphasized that this framework could serve as a reference for other states by promoting greater speed, uniformity, and efficiency in combating organized crime, especially in asset recovery and in weakening the financial structures of criminal organizations.

See more details: President of the Supreme Federal Court (STF) and the National Council of Justice (CNJ) attends the inauguration of specialized courts for combating organized crime in São Paulo.

First regional office of Brazil’s Financial Intelligence Unit strengthens fight against money laundering in São Paulo

Brazil’s Financial Intelligence Unit (COAF) has inaugurated its first regional office, marking a new milestone in institutional expansion. Located at the Central Bank’s headquarters in São Paulo, the new unit will focus on financial intelligence and oversight to prevent money laundering.

São Paulo was selected as a strategic location given that it houses Brazil’s largest financial market and a significant number of financial institutions and sectors under the agency’s supervision. According to COAF, the initiative aims to bring the agency closer to supervised institutions and authorities responsible for investigating financial crimes, ultimately strengthening institutional cooperation and improving mechanisms to prevent and detect suspicious transactions.

According to Coaf’s president, Ricardo Saadi, the regional office addresses the need to bring together key players involved in preventing and combating money laundering, given that São Paulo is home to the country’s largest financial institutions and authorities with a crucial role in this area.

See more details: São Paulo: Coaf’s first regional office inaugurated in the country’s financial hub.

STJ expected to rule on dispute raised by Santa Catarina regarding expert analysis in environmental crime prosecutions

Santa Catarina’s State Court of Justice (TJ/SC) has referred a special appeal to the Superior Court of Justice (STJ) under the repetitive appeals procedure, to determine whether an expert analysis is essential to prove the occurrence of the crimes outlined in Articles 38 and 38-A of the Environmental Crimes Law.

The debate arose from the conviction of a company for clearing secondary vegetation in the middle stage of regeneration within the Atlantic Forest. The conviction was upheld based on infraction notices, inspection reports, cartographic surveys, photographs, and testimonies, even without a formal expert analysis.

In referring the case to the STJ, Judge José Agenor de Aragão highlighted the existence of several appeals on the matter and divergent decisions within the court itself. While certain precedents require an expert report to prove environmental crimes that leave material evidence, others allow the offense to be demonstrated by other evidence deemed sufficient.

In this context, the aim is to allow the STJ to consolidate a precedent on the issue. Santa Catarina’s Court of Justice, however, emphasized that submitting the appeal to the STJ will not suspend proceedings in the matter, as it concerns a criminal case.

See more details: decision in full.

Cade publishes competition study on food delivery platforms

The Department of Economic Studies at Brazil’s Administrative Council for Economic Defense (CADE) has released a working document compiling international experience on competition issues in the food delivery market. The initiative aims to help understand the competitive dynamics of the sector and the approaches taken by antitrust authorities and regulatory bodies in other jurisdictions.

The study presents cases of mergers, investigations into anticompetitive conduct, advocacy initiatives, and regulatory proposals. It was developed through benchmarking with foreign authorities and research from public sources.

The goal is to identify competition challenges and regulatory instruments debated internationally, to help understand the development of the Brazilian delivery sector, which has gained prominence with the expansion of digital platforms in recent years.

See more details (PT-BR): Cade lança estudo sobre desafios concorrenciais no mercado de delivery de comida

CADE’s Tribunal reaffirms revenue criteria for merger notifications

CADE’s Tribunal approved the acquisition of 50% of Mitsubishi Fuso Bus Manufacturing by Lin Yin International Investments, a subsidiary of Foxconn. In addition to authorizing immediate implementation, the ruling clarified the criteria for mandatory merger notification, especially for cross-border transactions involving international economic groups with revenues in Brazil.

CADE’s General Superintendence found that the target company alone did not meet the legal revenue threshold of BRL 75 million in Brazil. It also emphasized that the acquired company is not located in Brazil and thus the transaction would have limited impacts on the Brazilian economy. Rapporteur Commissioner Carlos Jacques, however, emphasized that the analysis of these requirements under Law No. 12,529/2011 and CADE Resolution No. 33/2022 must factor in the economic groups involved, not just the acquired company. In this case, both the purchasing and selling groups exceeded the legal thresholds.

The rapporteur also emphasized that the assessment of notification criteria must be objective and focused on legal certainty. Regarding the territorial scope, the filing parties noted that the target company could operate in Brazil over the next five years, suggesting potential effects within the country. In its review of the merits, the Tribunal found that the transaction did not create any significant horizontal overlaps or vertical integrations in the affected Brazilian markets and approved the merger unconditionally.

This decision reaffirms the legal criteria that require merger notifications to CADE when, in the year preceding the transaction, one of the economic groups involved recorded annual gross revenue or turnover in Brazil of at least BRL 750 million, and at least one other group achieved revenue of at least BRL 75 million during the same period. The ruling also sparked discussions about a potential revision of Resolution No. 33/2022 to fine-tune the regulation of cross-border transactions that have limited or no impact in Brazil.

See more details (PT-BR): Cade aprova aquisição de 50% da Mitsubishi Fuso pela Foxconn

CADE investigates the exchange of sensitive information among competitors in the fragrance market

CADE’s General Superintendence has initiated an administrative proceeding to investigate alleged economic violations in the international fragrance market with effects in Brazil. The investigation involves three companies and six individuals suspected of participating in sensitive information-sharing agreements.

The investigation was launched based on evidence submitted under the 115th leniency agreement entered into within the Brazilian Competition Defense System (Leniency Agreement No. 02/2025). The suspects will be notified to present their defense, and the General Superintendence will issue its opinion after the investigation. The final ruling will be made by CADE’s Tribunal.

See more details: Cade instaura processo administrativo sobre condutas anticompetitivas no mercado internacional de fragrâncias

Cade recommends liability finding in cartel case involving the international sports media market

Cade’s General Superintendence recommended that the Tribunal find 6 companies and 18 individuals liable for participating in a cartel in the international market for sports media rights. The case involves rights associated with the FIFA World Cup and other sporting events, including broadcasting and content distribution rights negotiated in private tenders between media agencies and broadcasters.

According to the superintendence, the evidence shows that the group fixed prices and bids, divided markets, and exchanged sensitive information. The conduct allegedly occurred between 2008 and 2017 and involved rights related to the 2018 FIFA World Cup qualifiers, La Liga, the Coppa Italia, the Supercoppa Italiana, the Liverpool FC TV and Manchester United TV channels, as well as other sports.

The superintendence concluded that these practices could affect Brazil, as they pertained to international rights that could be sublicensed in the country or were linked to events held within Brazilian territory. Accordingly, the agency recommended sanctioning most of the defendants, while shelving the case against the remaining parties under investigation due to a lack of evidence. The case was referred to CADE’s Tribunal for a final ruling.

See more details: Cade recomenda condenação por cartel internacional no setor de mídias esportivas

Brazil’s Secex opens public consultation on sustainable products in the Mercosur-EU agreement

The Brazilian Secretariat of Foreign Trade (SECEX) has launched a public consultation to create a list of Mercosur products that contribute to the conservation, restoration, and sustainable use and management of forests and other vulnerable ecosystems. The consultation also aims to identify tariff, non-tariff, and cooperation measures that can improve the market reach, competitiveness, and visibility of these products in the European Union market.

Products on this list may enjoy preferential or additional access to the European Union market^[1].

Contributions to the consultation must be submitted by September 2, 2026, using the electronic form available on the Brasil Participativo website.

Mercosur–Japan agreement negotiations: public consultation ends on august 15

The Secretariat of Foreign Trade has opened a public consultation addressing the free trade agreement negotiations between Mercosur and Japan. This initiative provides a formal opportunity for companies and sectoral entities to register their offensive and defensive interests—including those related to tariff sensitivities, rules of origin, and non-tariff barriers—before Brazil’s negotiating position is finalized. The deadline for contributions ends on August 15, 2026.

Brazil disputes U.S. section 301 tariffs before the WTO

Brazil has requested consultations with the United States under the World Trade Organization’s (WTO) dispute settlement system regarding additional duties imposed on Brazilian products pursuant to two investigations under Section 301 of the Trade Act of 1974.

The tariffs include:

A 25% surcharge on all products originating in Brazil, barring exceptions, stemming from an investigation into alleged trade, regulatory, and intellectual property practices adopted by Brazil.
A 12.5% surcharge on specific products from Brazil — the result of an investigation into allegations of forced labor, which covered 60 economies.

The Brazilian government argues that the measures are inconsistent with GATT 1994 and the Dispute Settlement Understanding (DSU). The request for consultations formally initiates the dispute, setting a 60-day period to negotiate a mutually agreed-upon solution. If no agreement is reached, Brazil may request that a panel be established to review the case.

New safeguard investigations may affect brazilian exports to South Africa and The U.S.

In July 2026, South Africa and the United States notified the World Trade Organization (WTO) of the launch of the following safeguard investigations:

The potential application of safeguards could affect Brazilian exports of the products under investigation to these markets.

Updates: antidumping measures and public interest assessments

Below, we highlight the main acts issued by the competent Brazilian authorities on antidumping, including information on the procedures, the products involved, and their respective origins.

Secretariat of Foreign Trade (SECEX)

Dumping investigation into exports of welded line pipes from China to Brazil.

Initiation: CIRCULAR No. 51, DATED JULY 3, 2026

Product: welded line pipes, circular in cross-section, made of carbon steel, with a yield strength of less than 60 ksi, and a nominal external diameter of 14″ (355.6 mm) or more but not exceeding 48″ (1,219.2 mm), regardless of thickness or type of end, classified under subheadings 7305.11.00, 7305.12.00, 7305.19.00, 7305.31.00, 7305.39.00, 7306.19.00, and 7306.30.00 of the Mercosur Common Nomenclature (NCM).

Dumping investigation into exports of liquid and crystalline sorbitol from China and India to Brazil.

Initiation: CIRCULAR No. 56, DATED JULY 7, 2026

Product: liquid and crystalline sorbitol, classified under sub-items 2905.44.00 and 3824.60.00 of the NCM.

Sunset review of the antidumping measure applied to Brazilian imports of CNG cylinders originating in China.

Initiation: CIRCULAR No. 60, DATED JULY 23, 2026

Product: CNG cylinders, classified under subheading 7311.00.00 of the NCM.

Public interest assessment of the antidumping measure applied to Brazilian imports of milk powder originating in Argentina and Uruguay.

Initiation: CIRCULAR No. 62, DATED JULY 28, 2026

Product: whole or skim milk powder, not fractionated, classified under NCM sub-items 0402.10.10, 0402.10.90, 0402.21.10, 0402.21.20, 0402.29.10, and 0402.29.20.

Public interest assessment of the antidumping measure applied to Brazilian imports of nylon yarn originating from China, South Korea, and Chinese Taipei.

Opening: CIRCULAR No. 63, DATED JULY 28, 2026

Product: nylon filament yarns (polyamide 6 and polyamide 6.6), with a count of less than 50 tex, regardless of the number of filaments, profile, finish (bright, semi-dull, or dull), texture (flat or textured), twist (zero twist or less than 50 turns per meter), or coloration (dyed, unbleached, or bleached), classified under NCM subheadings 5402.31.11, 5402.31.19, and 5402.45.20.

Public interest assessment of the antidumping measure applied to Brazilian imports of polyester knitted fabrics originating in China.

Initiation: CIRCULAR No. 64, DATED JULY 28, 2026

Product: circular-knit fabrics made from synthetic yarns or filaments, with a predominance of polyester, classified under NCM sub-items 6004.10.31, 6004.10.32, 6004.10.33, 6004.10.34, 6004.90.30, 6006.31.20, 6006.32.20, 6006.33.20, and 6006.34.20.