With 70 cases adjudicated, Brazil's Office of the Comptroller General surpasses previous milestones and reinforces corporate integrity policies
The Office of the Comptroller General (CGU) reached a historic milestone by concluding the judgment of 70 Administrative Accountability Proceedings (PARs) in 2024, surpassing the previous record of 67 PARs adjudicated in 2023.
PARs are proceedings that determine corporate liability for harmful acts against public administration, as outlined in Brazil's Anti-Corruption Law.
This new record was achieved on Thursday (10th) following the publication of decisions in the Federal Official Gazette, in which four companies were held accountable for violating the Anti-Corruption Law. The sanctions included fines and prohibitions on participating in public bids or entering into contracts with the public administration.
This achievement by the CGU reflects the consolidation of accountability mechanisms for corrupt practices, strengthening the enforcement of the Anti-Corruption Law and boosting public policies aimed at corporate integrity.
Despite rumors of a decline in Brazil's fight against corruption in recent years, the CGU's efforts, in conjunction with other oversight bodies, demonstrate otherwise: there has been a strengthening of measures to prevent, detect, and punish unlawful conduct. In addition to the record number of PARs in 2024, the CGU initiated over 1,063 proceedings between 2020 and 2023, applying fines exceeding R$ 1 billion and launching several new anti-corruption operations in 2024, such as Operation Piemonte, the second phase of Operation Santa Rota, Operation Fito Fake, Operation Fiat Lux, and Operation Ghost Writer.
The growth of anti-corruption efforts, particularly by the CGU, is evident in the chart below, which illustrates the number of PARs adjudicated annually since the enactment of the Anti-Corruption Law in 2014.
To avoid liability for harmful acts against Public Administration, companies in Brazil increasingly need to invest in and dedicate efforts to the implementation and updating of their Compliance Programs. The importance of this initiative is highlighted by the launch of the Brazil Corporate Integrity Pact by the CGU at the beginning of 2024, which already has more than 180 Brazilian companies as signatories.
It is worth noting that the effective implementation, continuous improvement, and periodic review of Integrity Programs are factors considered by the CGU when setting fines in PARs, which may result in up to a 5% reduction in penalties for illicit practices under the Anti-Corruption Law.
The content of this article is intended to provide a general guide to the subject matter. Specialist advice should be sought about your specific circumstances.