Entries in Clean Company Act (10)
In a prior post earlier this year for the FCPA Blog, I talked about what Brazil is doing to clean up graft. This post continues that discussion, with a focus on official guidance from agencies and regulators about new anti-corruption laws and regulations and how to comply with them.
In two earlier posts, I looked at enforcement in Brazil during the prior calendar quarter. The first post described some of the enforcement actions and investigations that are ongoing, and the second post focused on graft scandals that could have a particular impact on the government.
As we mentioned in an earlier post on the FCPA Blog, on March 18 Brazilian President Dilma Rousseff issued a presidential decree regulating the Clean Company Act, as a part of a series of anti-corruption measures to counter the increasing number of protests against the federal government.
I spoke with Aaron Murphy, author of the book, Foreign Corrupt Practices Act: A Practical Resource for Managers and Executives and, as of 2014, a partner in the litigation practice of Akin Gump Strauss Hauer & Feld LLP's office in San Francisco.
The ongoing saga of Brazilian anti-corruption reform has reached a glorious crescendo. On Thursday, President Dilma Rousseff exercised her line-item veto power (a power the U.S. president lacks) to selectively approve Brazil's Clean Company Act. As a result, this long-time party to the OECD Convention has adopted legislation that creates corporate liability for bribery, cooperation credit for voluntary disclosure, a potential penalty reduction for the existence of a compliance program, and a host of very serious penalties.
A key vote has occurred in the Brazilian legislature on its anti-corruption bill, the Clean Company Act. And anti-corruption advocates may deem it only a partial success.