Compliance and Investigations Newsletter n.04

The Compliance and Investigations Newsletter provides information on the main news, trends, cases and legislation related to this segment, in Brazil and abroad. This material is for informational purposes and should not be used for decision making. Specific legal advice can be provided by one of our lawyers.

Enjoy your reading!
Compliance and Investigations Team


Brazilian branch of UN Global Compact publishes Anti-Corruption Good Practices Guide for the Agriculture and Livestock Industry

On April 18, 2022, the Brazilian branch of the UN Global Compact published the Anti-Corruption Good Practices Guide for the Agriculture and Livestock Industry (“Guide”). The document was drafted with contributions by 17 companies from the Agriculture and Livestock Industry and is aimed at promoting and strengthening ethics and integrity in business. The Guide addresses corruption and compliance risks mapped within the following segments: (i) citrus; (ii) industrial materials and inputs; (iii) pulp and paper; (iv) plant protein; (v) animal protein; and (vi) sugar-alcohol.

The Guide is divided into 8 chapters, listed below:

(i)     Interaction with Public Authorities and International Institutions;

(ii)    Combating corruption, money laundering and financing of terrorism;

(iii)   Environment, social responsibility, corporate governance and human rights;

(iv)   Defense of Free Competition;

(v)    Conflict of Interests;

(vi)   Donations and Sponsorships;

(vii)  Freebies, Gifts and Hospitality; and

(viii) Preventive Measures, Detection and Remediation.


The Guide can be downloaded here  and the kick-off conference recording can be accessed here.

Find out more by accessing the link.

Stericycle signs leniency agreements with United States and Brazil authorities to resolve bribery investigations

On April 20, 2022, the United States Department of Justice (“DOJ”) and the Brazilian Office of the Comptroller-General (“CGU”) announced that multinational waste management company Stericycle agreed to enter into leniency agreements concerning payments of bribes that occurred in Brazil, Mexico and Argentina. Stericycle agreed to pay over USD 84 million in compensation as a result of the agreements.

Of the total amount, BRL 109 million will be allocated to the CGU and to the Federal Office of the Attorney General. Stericycle has also made a commitment to update and improve its governance and compliance policies, as well as to its internal control mechanisms.

The leniency agreements can be accessed through the following links: (i) United States Department of Justice; and (ii) Office of the Comptroller-General (available soon).

UK publishes updated version of the list of sanctions imposed on people, entities and ships that violated the Anti-Money Laundering Act 2018

On April 26, 2022, the United Kingdom’s Foreign, Commonwealth & Development Office published an updated version of the sanction list in which people, entities and ships are designated or specified under the Anti-Money Laundering Act 2018. Research carried out by Demarest’s Compliance team indicate that no Brazilian individual, entity or ship was mentioned in the most recent version of the document.

The sanctions list can be accessed here.

MPF/PR publishes study reporting recovery of approximately BRL 25 billion to the public treasury from leniency agreements, plea bargain agreements and asset repatriation 

A recent study carried out by the Federal Public Prosecutor’s Office of the State of Paraná (“MPF/PR”) revealed that approximately BRL 25 billion was recovered to the public treasury as a result of leniency agreements, plea bargain agreements and repatriation of assets. According to a media report from magazine Veja, 43 leniency agreements and 156 plea bargain agreements were entered into with the MPF/PR. The recovered amounts were allocated mainly to Petrobras, the centerpiece in the Lava Jato Operation investigation, and to the federal government.

For more information, access here.