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Harry Cassin
Publisher and Editor

Andy Spalding
Senior Editor

Jessica Tillipman
Senior Editor

Bill Steinman
Senior Editor

Richard L. Cassin
Editor at Large

Elizabeth K. Spahn
Editor Emeritus

Cody Worthington
Contributing Editor

Julie DiMauro
Contributing Editor

Thomas Fox
Contributing Editor

Marc Alain Bohn
Contributing Editor

Bill Waite
Contributing Editor

Shruti J. Shah
Contributing Editor

Russell A. Stamets
Contributing Editor

Richard Bistrong
Contributing Editor

Eric Carlson
Contributing Editor

Brazil enforcement report for Q2 2015

Here are some notable items from April through June this year from Brazil in connection with corruption, enforcement, and compliance.

The Federal Comptroller’s Office (Controladoria-Geral da União – CGU), the Federal Public Prosecutor Office (Ministério Público Federal – MPF),  and the Federal Police (PF) have disclosed the following:

Cerberus operation: About BRL 20 million ($6.3 million) is suspected of having been diverted from public resources allocated to social programs in the state of Rondônia.

São Lucas operation: Improper receipt of salaries by doctors from Federal University of Paraná was disclosed. They were paid for years without exercising their functions. The government plans indictments for embezzlement, fraudulent misrepresentation, malfeasance, and neglect of civil service.

Semilla operation: A criminal network that operated in the Ministry of Agriculture was dismantled in the state of Rio Grande do Sul. The scheme is suspected of acting for the benefit of companies in the agricultural and agro-industrial sector by canceling fines, facilitating registrations and licenses, and informing companies in advance of inspections.

Fidúcia operation: about BRL 70 million ($22 million) was allegedly diverted from public resources by Civil Society Organizations of Public Interest’s partnerships with municipalities in the State of Paraná.

Tempestade operation: In its second phase, alleged irregularities in the purchase of building materials and services in the city of Camapuã (state of Mato Grosso do Sul) are being investigated. The operation aims to seize documents used in suspected fraudulent bids or misuse of public funds.

Paradise operation: The municipality of Araripina, in the state of Pernambuco, was the victim of a criminal network. The network allegedly diverted public resources that should have been used for the construction of schools, day care centers, and sports courts in the city. Investigations started in 2013 revealed bid rigging and the waiving of construction standards.

Caronte operation: PAC (Growth Acceleration Program) bids are under investigation in the state of Mato Grosso. Possible irregularities were found when one company was the only competitor in two bids. The company had been inactive and dormant for more than ten years and only recently began to participate and win bids, allegedly using false documents.

In the next post, I’ll review some other ongoing investigations and prosecutions that involve various government agencies and departments, as well as top politicians.


Lucas Zanoni is an undergraduate student of law at University of São Paulo and a legal intern in the compliance and anti-bribery team of Chediak Advogados. The firm offers legal assistance for both Brazilian and international clients across different industries and business sectors.

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