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Harry Cassin
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Andy Spalding
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Jessica Tillipman
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Richard L. Cassin
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Cody Worthington
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Thomas Fox
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Marc Alain Bohn
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Russell A. Stamets
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Enforcement agency restructured in Brazil corruption fight

The Federal Comptroller’s Office (CGU) is an internal control body of the Brazilian Federal Government responsible for carrying out activities related to the defense of public patrimony and increasing the transparency of management, through public corrective actions, prevention and fight against corruption and ombudsman.

The Decree No. 9,681 / 2019 which entered into force on January 30, 2019 changed the CGU’s structure. The main novelty of the decree is the creation of a new secretariat, which will absorb the responsibility for the anti-corruption activities, bringing together leniency agreements, strategic information and special operations.

The Secretariat of Combating Corruption is composed of three directories (Directory of Leniency Agreements, Directory for Research and Strategic Information, and Special Operations Directory) and was created to better articulate technical work and standardize normative acts in investigation activities, such as special operations and intelligence developed by CGU.

The decree may strengthen the persecution of numerous cases of corruption. According to the mapping done by the CGU and Brazilian State Defense agencies such as the Federal Police and Public Prosecutor’s Office, during the last 15 years, 352 investigative actions of special operations were launched. Of these, 32 were triggered in 2018.

It is estimated that the total loss recorded in all these operations was around $1.33 billion.

Overall, the decree tends to enhance the structure of the CGU, as well as increase the efficiency of the body in order to provide more subsidies for the prevention, detection and punishment of irregularities due to the misapplication of federal public resources, especially regarding prevention and the fight against corruption, and to increase the transparency of management within the federal public administration.


Cláudia Carneiro, pictured above right, is the founder and coordinator of ComplianceLab-Mack, which is the first compliance group of the Mackenzie Law School. She can be contacted here

Bianca Bonugli, left, is an associate lawyer at Trench Rossi Watanabe. She can be contacted here

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