In Brazil, the act of bribery integrates the concept of corruption, typified under Brazilian Penal Code in Title IX, which defines the felonies against the national public administration. It criminalizes corruption in the public official’s spectrum (designated as “passive corruption”), specifically in its Article 317, while the Article 333 prohibits the practice on the private individual’s side (known as “active corruption”).

In addition to that, with the purpose of repressing corruptive actions at the organizational level, Civil and Administrative laws fight corruption through three special legal instruments: (i) the Anti-Corruption Act No 12.846/13, which deals with the civil and administrative liability of companies that practice bribery and acts of corruption; (ii) the Bidding Act No 8.666/93, which regulates Article 37, XXI, of the Brazilian Federal Constitution and establishes rules for Public Administration biddings and contracts; and (iii) the Administrative Improbity Act No 8.429/92, which provides for the sanctions applied due to the practice of acts of administrative impropriety, dealt with at paragraph 4 of Article 37 of the Federal Constitution.

In our jurisdiction, corruption can be investigated by the judicial police authorities which provide the Public Attorney’s Office with the evidences collected during any investigations, or straight by the Public Attorney’s Office in its own investigative procedure.

By the way, according to Article 5, paragraph 3, of the Criminal Procedure Code, any Brazilian citizen can communicate an occurrence of a crime and request a formal investigation to any of the aforementioned agencies.

“Bribery” or “corruption” refers to a range of illicit activities, typically classified as criminal offenses under the law, involving the direct or indirect solicitation, offering, or acceptance of unlawful benefits or advantages. These activities encompass various criminal behaviors, such as abuse of power, bribery, influence peddling, and the improper use of public or private resources to gain personal benefits or advantages for oneself or others, often occurring within the realm of Public Administration.

From the perspective of Criminal Law doctrine, as per the stipulations of the Brazilian legal system, corruption is typically categorized into two main modalities: (i) passive corruption, as outlined in Article 317 of the Penal Code, and (ii) active corruption, as outlined in Article 333 of the Penal Code. These distinctions serve to delineate between the different roles and actions involved in corrupt practices, providing a framework for legal enforcement and prosecution.

Yes, the Brazilian legal system distinguishes the offense of active and passive corruption involving a public official and a private agent. For the occurrence of active corruption, it must be the private agent who conceives the illicit advantage for the public official; for passive corruption to occur, it has to the public official or the person in a position of public authority who solicits or accepts the bribe.

Thus, to ensure legal certainty with the complete establishment of its concepts, Brazilian law defines a public official, for criminal purposes, as “someone who, although temporarily or without remuneration, holds a position, job, or public function” (Article 327 of the Penal Code).

In other words, a public official can be designated as such when invested in a public position, consisting of the personal, specific, and corresponding assignment, as established by law, for the promotion and exercise of duties conferred by the State upon the person.

Regarding this, the Penal Code draws a distinction between a public official and a foreign public official. The Law No. 10.467/2002 establishes the concept of a foreign public official as someone who “although temporarily or without remuneration, holds a position, job, or public function”, but in State entities or diplomatic representations of foreign countries (Article 337-D of the Penal Code). A foreign public official is also considered one for holding a position, job, or function in companies controlled by a foreign State, such as those who work in international public organizations like the World Bank, OTAN, ONU and OIT (Article 337-D of the Penal Code).

Furthermore, the Brazilian normative system does not make a specific distinction between public officials and private agents for the purpose of criminal liability involving the crime of corruption, although many countries do. Thus, in Brazil, there is no classification of “private corruption” as a crime, unlike countries such as the United Kingdom, Germany, and the United States.

Under Civil law, both individuals and legal entities can be held liable for bribery under the Anticorruption Act No 12.846/2013. The Law aims to regulate liability for acts of corruption in the administrative and civil spheres and establishes strict responsibilities for legal entities, which may be punished for acts of corruption committed by their representatives and employees, regardless of proof of fault or malice on the part of the company.

The felonies of passive and active corruption, which can also criminally qualify the conduct of offering a bribe, are attributed to qualified public officials under Article 327 of the Penal Code and to any private agent.

Concerning the crime of passive corruption, this occurs when a public official offers, requests, or receives, directly or indirectly – by virtue of their status as a public official – an undue advantage or promise of such advantage. In active corruption, the private agent, or simply “agent”, offers or promises an undue advantage to a public official to induce them to perform, omit, or delay an official act for their own benefit or another’s person benefit.

As pointed out, there is no crime of “private corruption” in the Brazilian legal system, so private agents cannot be held responsible for acts of corruption committed in the private sector that do not involve the Public Administration or another crime.

Firstly, it is indispensable to emphasize that the administrative, civil and criminal responsibilities arising from the same illegal act are treated separately and independently under Brazilian jurisdiction. Therefore, the judicial and extrajudicial instances that deal with such acts are distinct and should not be mixed.

In this degree, Civil liability arising from acts of corruption consists of the obligation to economically repair the damage caused to the Public Administration, in which confiscation and/or forfeiture of illegally acquired assets, removal from public office, payment of a fine, prohibition from contracting with the public administration, and prohibition from benefiting from tax incentives or public funding are the consequences.

If we talk about active corruption, bribery can result in a penalty of up to twelve years, which may be increased by one-third if, as a result of the advantage or promise, the Official delays or omits an official act or performs it in violation of his or her functional duties.

In the other hand, if we talk about passive corruption, bribery can also result in a penalty of up to twelve years, but the cause to increase the penalty differs from passive corruption. In this scenario, the penalty is increased by one third if, as a result of the advantage or promise, the public official delays or fails to perform any official act or performs it in breach of his official duty. The penalty is also increased by one third if the public official performs, fails to perform or delays an official act, in breach of his functional duty, yielding to the request or influence of others.

The Brazilian Criminal Procedure Code and related legal previsions provide mechanisms for court settlement with the Prosecutor’s Office.

In this regard, the Brazilian legal system instituted the Non-Persecution Agreement (Article 28-A of the Criminal Procedure Code), which consists of a formal legal-processual agreement between the Prosecutor and the accused(s) – approved by the Judge – enabling the extinction of the accused’s possibility of being punished and the consequent closure of the process that involves felonies without violence or threat, with a minimum penalty of less than 4 years. This is a viable agreement in actions involving active and passive corruption crimes, as both offenses stipulate a minimum penalty of 2 years and are not committed with violence or serious threat.

Moreover, the Collaboration or Plea Bargaining established by Law No. 12,850/2013 (see: Articles 3º-A to 7º) is a “legal transaction and form of evidence (proof), presupposing public utility and interest,” an interest which, in proceedings investigating the practice of corruption, involves obtaining privileged information from accused/investigated individuals in exchange for penal benefits enabled by such legal transaction.

In Brazil, the law does not delineate specific regulations regarding expenditure on hospitality, travel, and entertainment for either domestic or foreign public officials. The primary requirement is that funds allocated for such expenses are approved in advance and that the individual authorizing them possesses the legal authority to do so.

However, it is within the jurisdiction of the Federation, States, and Municipalities to establish limitations and guidelines pertaining to these types of expenditures. While there may not be nationally mandated restrictions, regional or municipal authorities may impose their own regulations to ensure proper oversight and accountability in such matters.

Political contributions are regulated in Brazil. The Brazilian electoral laws outline specific guidelines for financing election campaigns, including regulations on donations made by individuals and legal entities, and restrictions on the amount of such contributions.

Following the 2017 Electoral Reform, legal entities are no longer allowed to make donations to political campaigns. Contributions can now only be made by individuals and are limited to 10% of the individual’s gross income from the previous year. Additionally, donations must be made via electronic transfer or identified deposit into the candidate’s or political party’s bank account.

These campaign financing regulations aim to ensure transparency, fairness, and equality in the electoral process, while preventing the use of illegal resources and avoiding favoritism towards particular candidates or parties.

Under Brazilian law, facilitation payments are strictly prohibited due to the potential conflict of interest they create between public and private entities. Any form of payment or promise made to a public official with the intent to influence their actions or decisions is considered an act of corruption.

Therefore, offering money to expedite processes such as obtaining documents, licenses, permits, or certificates is expressly forbidden. Brazilian legislation emphasizes the importance of integrity and transparency in dealings with public officials, aiming to prevent any form of bribery or undue influence in administrative procedures.

In Brazil, the Federal Constitution guarantees the right to a comprehensive defense for all individuals subject to its jurisdiction, as stated in Article 5, item LV. However, there are no specific statutory provisions that establish affirmative defenses for cases of corruption.

Nevertheless, jurisprudence has delineated certain limitations to accusations of corrupt practices. For instance, the Public Prosecution Office is required to define the scope of the “official act” involved, rather than indiscriminately labeling any payment received by a public official as corrupt. This underscores the importance of precise legal interpretation and procedural fairness in corruption cases within the Brazilian legal system.

In Brazil, compliance programs play a crucial role in mitigating liability for bribery offenses. The enactment of Act No. 12.846/2013 marked a significant milestone, being the first law to regulate integrity or compliance programs in the country, aimed at establishing clear guidelines and standards.

While the implementation of compliance programs is not mandatory, they serve as a vital tool in promoting transparency in business management. Moreover, their adoption can be viewed as a mitigating factor in the event of a conviction for violations outlined by law.

It’s worth noting that employees and collaborators may inadvertently engage in illegal activities, highlighting the importance of specialized compliance counseling to prevent legal issues. Keeping compliance programs updated in accordance with both external regulations and internal policies is paramount.

To ensure effectiveness, it’s essential to establish mechanisms allowing employees and third parties to report irregularities to the compliance committee securely. Failure to comply with anti-corruption regulations can result in hefty fines, underscoring the necessity of a well-structured compliance program.

Key components of an effective anti-corruption compliance program include the implementation of a Code of Ethics and Conduct, the establishment of whistleblower channels, ongoing training and development initiatives, thorough due diligence of suppliers, continuous monitoring, auditing processes, and comprehensive risk assessments.

The Brazilian government has taken proactive measures to provide guidance on adhering to anti-corruption laws through various channels. One notable example is the “Private Entities Responsibility Manual,” accessible on the Federal Government website and published by the General Controller of the Union.

Furthermore, in 2016, the Administrative Council for Economic Defense (CADE), operating under the Ministry of Justice, released a “Compliance Program Guide.” This guide encourages the implementation of compliance programs, even for small and medium-sized enterprises, underscoring the importance of proactive measures in preventing corruption.

Moreover, the Office of the Comptroller General of Brazil issues a wide array of norms, guidelines, and codes of conduct annually to promote integrity in relationships between public administration and private entities.

Given Brazil’s commitment as a signatory to three international anti-corruption treaties — namely, the OECD Convention on Combating Bribery of Foreign Public Officials in International Business Transactions, the Inter-American Convention against Corruption of the OAS, and the United Nations Convention against Corruption (UN) — companies are expected to align their compliance policies with these treaties in a transparent and concise manner.

Ensuring an ethical environment within companies is vital in the fight against corruption. To achieve this, companies may implement measures such as establishing a Code of Ethics and Conduct, providing reporting channels for whistleblowers, conducting regular training and development programs, conducting due diligence on suppliers, implementing robust monitoring and auditing processes, and conducting thorough risk assessments, among others.

In Brazil, legislation provides robust protection mechanisms for whistleblowers, witnesses, and crime victims. Reporting irregularities reflects citizens’ trust in the Public Administration, with an expectation that reported issues will be appropriately investigated and sanctioned. To reciprocate this trust, the Public Administration ensures provisions to safeguard the identity of whistleblowers.

The ‘Fala.BR’ platform exemplifies such provisions, offering features designed to preserve users’ anonymity. This platform allows citizens to request public information and register complaints, aligning with the Access to Information Law and the Public Service Users Defense Code.

Additionally, the Comptroller General of the Union oversees the creation of processes to investigate complaints and ensures protection against retaliation, among other measures. In cases of non-compliance, whistleblowers have the option to report to the central body of the Federal Executive Branch Ombudsman System.

Moreover, the Anti-Corruption Law (Law No. 12,846/2013) incentivizes companies to establish reporting channels by considering the presence of such mechanisms in the determination of potential administrative sanctions (Article 7, VIII).

Furthermore, Law No. 13,608 of 2018 provides comprehensive regulations on this matter. Article 4 of this law allows the Union, States, Federal District, and Municipalities to establish reward systems for individuals offering information useful in the prevention, repression, or investigation of crimes or administrative offenses.

Investigations conducted by government authorities into allegations of corruption in Brazil have become increasingly prevalent in recent years, particularly following the initiation of ‘Operation Car Wash’ in 2014.

However, the effectiveness of these investigations has been subject to debate, influenced by factors such as media coverage of cases with international ramifications and the phenomenon of ‘Lawfare’—a strategy involving the misuse of legal mechanisms to achieve specific objectives, often seen in judicial proceedings.

While combating corruption remains a critical priority, it’s essential to recognize that the politicization of the legal system can strain institutions tasked with anti-corruption efforts, including the Public Prosecutor’s Office and the Judiciary. This can erode public trust in these institutions and impede the efforts of prosecutors and judges genuinely committed to combating corruption.

Thus, while government authorities regularly initiate investigations into corruption allegations in Brazil, the effectiveness of prosecuting individuals and entities implicated in corrupt practices can be influenced by a myriad of factors, including political dynamics and institutional challenges.

Nowadays, there is an increasing use of technology in the investigation and repression of corruption. This includes using data analytics and artificial intelligence investigations to identify patterns of corruption and facilitate investigative methods.

Artificial intelligence, through sophisticated algorithms and advanced data processing capabilities, has been successfully employed in identifying suspicious transactions, tracking illicit resources and detecting possible corruption schemes. Furthermore, the resource makes it possible to identify trends and patterns adopted by corrupting agents, helping to prevent and combat corruption.

However, it is important to highlight that the success of these initiatives depends not only on the technology itself, but also on a conducive institutional environment that promotes transparency, integrity and accountability for those involved.

In Brazil, the legal system offers various avenues for challenging government authority actions and decisions through a range of lawsuits and appeals available in both administrative and judicial spheres. These mechanisms aim to provide recourse for individuals who have been adversely affected by government actions or decisions deemed unfair or unlawful.

Typically, for judicialized acts, individuals may resort to filing a writ of mandamus (‘mandado de segurança’). This expedited legal process is designed to rectify specific illegalities and is subject to the jurisdiction of the governmental authority responsible for the contested action.

In the realm of criminal law, individuals have the option to pursue a criminal review (‘revisão criminal’) under specific circumstances. This includes scenarios where new relevant evidence surfaces subsequent to a final and unappealable criminal conviction, instances of a miscarriage of justice significantly influencing the conviction, or the enactment of a more favorable law after the conviction has been finalized.

In the past 12 months, significant developments have occurred in our jurisdiction regarding anti-corruption legislation. Notably, Bill No. 4.436/2020 is currently under consideration in the Federal Senate. This bill aims to establish provisions for prosecuting private corruption within the Brazilian Penal Code.

Progress has been made on this front, as the bill was approved by the Public Security Commission on March 12, 2024, and subsequently forwarded for final deliberation by the Constitution of Justice Commission. These developments signal a concerted effort to address and combat corruption within private entities, reflecting ongoing legislative reforms in this critical area.

Recently, as stated in the previous question, Bill 4.436/2020 was approved by the Public Security Commission, which typifies private corruption in the Brazilian legal system.

The bill amends the Penal Code to establish a penalty of 2 to 5 years of imprisonment and a fine for anyone who demands, requests, or receives and undue advantage, as an employee or representative of a private company or institution, to favor themselves or third parties, directly or indirectly, or accepts a promise of such an advantage, to perform or omit an act inherent to their duties.

In addition, anyone who offers, promises, delivers, or pays, directly or indirectly, to the employee or representative of a private company or institution, such an advantage, will also receive the penalty.

Brazil is a signatory of three international treaties against corruption: (i) OECD Convention on Combating Bribery of Foreign Public Officials in International Business Transactions; (ii) OAS Interamerican Convention against Corruption and (iii) United Nations Convention against Corruption (UN).

The conventions mentioned above are important components of the public heritage protection microsystem, which consists of a set of conventional, constitutional and infra-constitutional rules that aim to safeguard the public heritage.

In Brazil, the concept of legal privilege concerning lawyer-led investigations is still in the process of development. In 2018, the Brazilian Bar Association introduced regulations regarding this practice, known as Defensive Investigation, although its widespread recognition within our jurisdiction is still evolving.

Defensive investigation involves lawyers and legal teams gathering evidence and pertinent information to support a client’s defense in legal proceedings, investigations, or litigation. This proactive approach encompasses activities such as document review, witness interviews, analysis of physical evidence, obtaining public records, and consulting experts, tailored to the specifics of each case. The objective is to compile information that can strengthen the client’s position and counter accusations effectively.

In a significant development in 2021, our firm achieved an unprecedented decision from the 5th Panel of the Federal Regional Court of the 3rd Region, citing Provision 188 of the Federal Council of the Brazilian Bar Association. This decision granted authorization for our team to conduct defensive investigations, including accessing evidence from materials produced by private companies, to bolster our client’s technical defense as required.

The Brazilian government acknowledges the significant importance of combating bribery and corruption, recognizing that such efforts must adhere to the legal framework of guarantees and rights. It is imperative to ensure that anti-corruption measures are implemented without violating the constitutional principles that underpin the country’s legal system.

In recent years, Brazil has intensified its efforts to address public corruption, particularly since 2014. However, this journey has been marked by challenges stemming from legal issues and systemic problems within law enforcement agencies. Instances of abuse of power by certain authorities, including the Police and the Public Ministry, have resulted in procedural nullities due to violations of defendants’ fundamental rights and guarantees. The Supreme Court has played a crucial role in addressing these abuses and upholding the rule of law.

Despite progress, Brazil still faces structural and cultural challenges in combating corruption. Structural issues within government bodies persist, and there is a need to address cultural aspects, particularly the prevalence of an inquisitorial culture within the legal system. This culture can compromise the rights and guarantees inherent to a democratic state governed by the rule of law.

In comparison to other jurisdictions, Brazil recognizes the need for continued improvement in combating corruption. Addressing systemic challenges and fostering a culture of transparency and accountability are essential for ensuring a truly independent and fair fight against public corruption. By upholding the rule of law and promoting democratic principles, Brazil aims to strengthen its position on the international stage in combating bribery and corruption.

In assessing the seriousness of organizations in our country regarding the prevention of bribery and corruption, it is important to recognize that this can vary significantly based on individual perspectives and organizational cultures.

Both the public and private sectors have increasingly embraced the concept of ‘compliance’, derived from the English verb ‘to comply’, which entails conforming to rules and regulations with the aim of preventing and mitigating the impact of corruption.

The adoption of compliance practices is fundamental in engaging organizations in the fight against corruption. It is acknowledged that organizations can be susceptible to illicit activities, and merely punishing individuals may not suffice to instigate the desired cultural shift towards ethics and integrity. Therefore, by imposing organizational responsibility, compliance initiatives seek to incentivize the implementation of measures aimed at fostering a culture of ethical conduct.

The term ‘compliance’ encompasses a range of internal procedures designed to ensure adherence to legal and regulatory standards, as well as to prevent deviations from established ethical and integrity norms within the company. These measures serve to promote accountability and transparency, thereby contributing to the prevention and detection of bribery and corruption within organizations.

In Brazil, enforcement agencies and regulators encounter significant challenges when investigating and prosecuting cases of bribery and corruption. One of the primary hurdles involves unraveling complex corruption schemes to grasp the full extent of the intricate networks typically involved in crimes against public administration.

In criminal cases pertaining to bribery or corruption, authorities tasked with investigations must gather substantial evidence to meet the requisite burden of proof necessary for initiating criminal proceedings. This includes satisfying the legal standards for evidence, even during the preliminary stages of investigation, such as the formal presentation of charges by the Prosecutor’s Office and their subsequent acceptance by a Judge.

Addressing this challenge necessitates a meticulous approach to case reconstruction, encompassing a comprehensive historical analysis. This entails presenting a compelling body of evidence in court to substantiate the continuation of criminal proceedings.

Efforts to tackle these challenges often involve enhanced collaboration among law enforcement agencies, leveraging advanced investigative techniques, and deploying specialized task forces dedicated to combating bribery and corruption. Additionally, measures aimed at strengthening legal frameworks, improving transparency, and enhancing international cooperation can contribute to more effective enforcement efforts.

The implementation of internal rules and the concept of ‘compliance’, aimed at ensuring adherence to applicable laws and regulations, pose several challenges for businesses striving to meet organizational expectations. However, the most significant and daunting hurdle lies in fostering a cultural shift towards genuinely ethical and transparent practices.

For instance, the OECD Handbook underscores the importance of self-regulation, citing the International Ethics Standards Board for Accountants’ standard on ‘Responding to Non-Compliance with Laws and Regulations (NOCLAR)’. According to NOCLAR, accounting professionals have a duty to proactively report illegal activities, such as fraud, to the appropriate authorities.

Within this framework, Compliance professionals play multifaceted roles in managing compliance programs. They serve as advocates, providing guidance and addressing employees’ inquiries, while also facilitating proactive engagement with teams and advocating for the company in the face of potential risks. Most importantly, they serve as motivators, guiding individuals through the compliance journey and fostering a culture of adherence.

Moreover, the engagement and training of personnel are paramount for the success of compliance initiatives. By delineating internal procedures and establishing guidelines to enforce legal and regulatory standards, investing in people becomes synonymous with investing in the company’s most valuable asset.

In response to the mounting challenge posed by the proliferation of electronic data in investigations and prosecutions related to bribery and corruption, Brazilian authorities have proactively pursued advanced technical expertise. This includes efforts to unlock and map metadata, digital evidence, and blockchains, which are vital for conducting thorough investigations and subsequent judicial proceedings.

Furthermore, recognizing the critical importance of preserving digital evidence collected during investigations, authorities have implemented measures to ensure its integrity. A notable development in this regard is the establishment of the ‘Evidence Custody Chain’ outlined in the Code of Criminal Procedure (Articles 158-A to 158-F). This initiative, introduced through the ‘Anti-Crime Package’ (Law No. 13,964/2019), aims to safeguard electronic evidence and maintain its chain of custody throughout legal proceedings.

Moreover, Brazil has actively engaged in fostering international cooperation to address digital crimes that may transcend national borders. The country participates in various forums and international organizations, including Interpol, the Organization of American States (OAS), and the Budapest Convention on Cybercrime. Through these collaborative efforts, Brazilian authorities aim to enhance their capacity to combat bribery and corruption offenses that involve electronic data, fostering a more robust and effective response on both domestic and international fronts.

In the Brazilian jurisdiction, businesses are poised to face significant bribery and corruption-related challenges over the next 18 months, primarily stemming from potential legislative developments. A notable concern is the looming possibility of the National Congress criminalizing corruption within private institutions involving their agents.

Moreover, the prevailing legal-business culture in Brazil currently permits practices that could arguably be construed as instances of private corruption. While such behaviors may fall under other legal offenses, the absence of a defined criminal classification for private corruption poses a notable challenge for businesses navigating compliance and legal frameworks.

Furthermore, there is a pressing need for the restructuring of the legal system to accommodate the anticipated increase in cases resulting from the potential criminalization of private corruption. This entails a comprehensive review and reform of existing legislation, particularly the Organized Crime Law (Law No. 12,850/2013) and the Anti-Corruption Law (Law No. 12,846/2013), which currently serve as the primary legal frameworks for addressing corruption-related offenses. Adapting these laws to specifically address private corruption would be essential to effectively combatting such practices within the business sector.

Navigating these evolving legal landscapes and ensuring compliance with emerging regulatory frameworks will present significant challenges for businesses operating in Brazil over the coming months.

To enhance the legal framework and process for preventing, investigating, and prosecuting cases of bribery and corruption in Brazil, several key reforms and initiatives could be implemented.

Firstly, strengthening control and inspection bodies and ensuring the protection of whistleblowers are essential pillars. Encouraging collaboration with investigations by providing robust safeguards for whistleblowers is crucial to uncovering illicit activities and holding perpetrators accountable.

Moreover, fostering intense collaboration between oversight entities is imperative. This necessitates the integration of internal and external oversight bodies to facilitate information-sharing and coordinated efforts in combating corruption effectively.

To achieve these goals, the establishment of a federal committee comprising representatives from the Comptroller General, the Federal Audit Court, the Federal Public Prosecutor’s Office, the National Council of Justice, and the Brazilian Intelligence Agency would be advisable. This committee would serve as a central coordinating body, facilitating collaboration and cooperation among diverse entities involved in anti-corruption efforts.

Additionally, extending these collaborative mechanisms to the state, district, and municipal levels through the creation of respective committees would ensure comprehensive participation across all levels of government. These committees could be further empowered by establishing specialized working groups dedicated to uncovering and deterring corrupt practices. By adopting robust procedures and security measures and fostering information-sharing within relevant sectors, these working groups can enhance the effectiveness of anti-corruption efforts.

Overall, these proposed reforms and initiatives aim to strengthen Brazil’s legal framework and processes for combating bribery and corruption, fostering a more coordinated, collaborative, and proactive approach to addressing these pervasive challenges.