On July 27, 2021, the Brazilian Office of the Comptroller-General (“CGU”) launched the International Recommendations Dashboard, a transparency tool that publicizes the full recommendations received by Brazil under the following international anti-corruption conventions: (i) the Inter-American Convention against Corruption (OAS); (ii) the United Nations Convention against Corruption (UN); and (iii) the Convention on Combating Bribery of Foreign Public Officials in International Business Transactions (OECD).
The tool collates all the recommendations established in each international convention ratified by Brazil, as well as their respective implementation status. In addition, the tool enablessearches for information on: (i) the recommendation’s subject matter; (ii) the Brazilian government bodies involved in implementing the recommendation; and (iii) whether the recommendation falls within the scope or not of the Brazilian Anti-Corruption Plan 2020-2025, launched in December 2020, with the purpose of improving mechanisms of the Brazilian Federal Executive Branch for the prevention, detection and accountability for acts of corruption in Brazil.
The recommendations are classified under six categories: (i) legislative measures; (ii) procedural suitability; (iii) guidelines and procedures; (iv) strengthening of institutions; (v) data production; and (vi) inter-institutional cooperation.
Each international convention has its own methodology for evaluating adherence to the agreed principles and, based on the periodic assessments, reports are issued containing recommendations to each Member State .
It should be noted that information concerning the status of implementation of the recommendations that are made available in the International Recommendations Dashboard has not been formally validated by the international bodies, and may be modified in accordance with the next evaluation rounds. Thus, to supplement any technical assessment not yet carried out, the CGU has included information provided by the Brazilian government bodies involved in the implementation process.
Demarest’s Compliance and Investigations team is available to provide further information on this and other related matters.