Compliance in Brazil
Azevedo Sette Advogados
In a significant move, Azevedo Sette Advogados invested in its compliance practice with the 2019 hire of leading lawyer Isabel Franco from KLA-Koury Lopes Advogados. She brings vast experience in investigations, crisis management and anti-corruption due diligence in the context of large M&A, and is one of the pioneers in this field in Brazil. Working alongside Franco is economic law, anti-corruption and compliance specialist Luiz Eduardo Salles. In recent work, Salles led the team advising a client on the implementation of a global whistleblower hotline. Ana Paula Terra Caldeira is a key contact in the Belo Horizonte office.
TozziniFreire Advogados' leading compliance and investigation practice 'has great depth in its analysis and conduct of projects'. The firm was among the first to establish a dedicated group, and it now fields a large team of experts in compliance, anti-corruption, regulatory and criminal enforcement. Many of its clients have been working with the firm for years or decades, though it also continues to attract new clients, including in the tech and life sciences sectors. In November 2018, the firm announced the creation of the Latin American Compliance & Investigation League (LACIL), an initiative to bring together leading players in the compliance field and share best practices. Recent highlights for the department include conducting an internal investigation for a large Brazilian company following a whistleblower and media allegations; Renata Muzzi Gomes de Almeida and 'natural leader' Shin Jae Kim led the work. Giovanni Paolo Falcetta and Karla Lini Maeji are also key contacts.
The 'excellent and cohesive' compliance team at KLA Advogados can count on 'very skilled and experienced professionals' and is noted for its 'prompt responses'. It was one of the first compliance departments to be established in Brazil, thanks to the leadership of Isabel Franco, who moved to Azevedo Sette Advogados in 2019. The team continues to provide a broad service across compliance, investigations and white-collar matters, and recently hired risk assessment experts Catarina Rattes and Natália Amici from EY. On the white-collar front, Filipe Magliarelli is an expert in criminal procedure and economic crime. One notable recent mandate saw the team assist a company with multi-jurisdictional operations establish monitoring capabilities as part of the enhancement of its compliance program; the group also has notable experience in complex investigations and compliance training. Post publication, however, the practice has endured the December 2019 departure of Eloy Rizzo -who had been leading the team since Ms Franco's departure- for Demarest Advogados.
Mattos Filho, Veiga Filho, Marrey Jr. e Quiroga Advogados has 'an extremely good knowledge of the Brazilian market and market practices', and clients also highlight the firm's technical skills as a 'key competitive advantage'. With a team is split between the São Paulo, Brasília and Rio de Janeiro offices, the broad compliance and corporate ethics practice covers everything from prevention to crisis management. Highlights included representing an oil-and-gas company in a multilateral investigation into allegations of bribery and in the negotiation of a leniency agreement. Thiago Luís Sombra focuses his practice on anti-corruption, public law and data protection. Thiago Jabor Pinheiro, Renato Tastardi Portella and Kevin Michael Altit are recommended.
The highly regarded compliance practice at Pinheiro Neto Advogados sits within the litigation department and encompasses administrative and judicial litigation, investigations and preventative work. The team also works alongside colleagues in the corporate department to advise on compliance issues in M&A. In one example, José Alexandre Buaiz Neto and Mário Panseri Ferreira conducted the compliance due diligence on the acquisition of a minority stake in Grupo Madero by client Carlyle. Other contacts in the multidisciplinary group include public law and anti-corruption expert Ricardo Pagliari Levy and Vicente Coelho Araujo, who has vast experience in internal investigations.
The well-established and specialised compliance practice at Saud Advogados has 'very strong knowledge about FCPA, UK anti-bribery and Brazilian anti-corruption legislation' and is noted for its 'quick and objective responses'. The firm's main base is Rio de Janeiro, and its cooperation with Hughes Hubbard & Reed LLP gives it access to an extensive US office network. In ongoing work, the team has been advising a multinational financial services company on legal and compliance developments in Brazil. 'Amazing lawyer' and 'brilliant mind' Salim Jorge Saud Neto and 'experienced' and 'business-driven' Bernardo Viana are key figures. The firm also benefits from a team of experienced associates.
The compliance, investigations and governmental enforcement practice at BMA - Barbosa, Müssnich, Aragão is led by Anna Carolina Malta and José Guilherme Berman and comprises specialists in different fields of law. For example, the team saw an uptick in moral and sexual harassment investigations in 2018, and worked alongside colleagues in the labour department. Much of the team's work is cross-border in nature, and it counts domestic and international companies among its clients. Adriana Dantas left to join the Petrobras ethics committee.
Cescon, Barrieu, Flesch & Barreto Advogados 'has leveraged its existing prominence in capital markets and other areas to build a solid compliance team'. The department receives plaudits for its 'great focus' and 'interest in understand the specific needs of the client'. Its workload spans compliance programs, due diligence, investigations and legal opinions, and its clients include domestic and international companies and foreign law firms. Luciano Inácio de Souza was promoted to partner in February 2019 and is recommended.
The highly recommended compliance practice at Demarest Advogados combines knowledge of anti-corruption, criminal, competition and public law. Sector specialisms include infrastructure, oil and gas, banking and sports. Practice head Carlo Verona 'delivers work with superior quality and sharpness' and 'builds strong relationships with his clients', while Paola Pugliese focuses her practice on competition and compliance. Significant mandates saw Fabyola En Rodrigues and a team assist an international construction company with an internal investigation as well as with matters related to Operação Lava Jato. Post publication -in December 2019- the firm has announced the highly notable incorporation of Eloy Rizzo; formerly at KLA Advogados, he is regarded as a leading figure in the sector and will co-head the firm's compliance practice in conjunction with Verona.
Dias Carneiro Advogados handled a number of corporate investigations during 2017 and 2018, and the firm illustrated its commitment to the compliance practice when it promoted Joyce Ruiz Rodrigues Alves to partner in 2018. She is often retained by domestic and foreign companies to advise on and review compliance programs. Ricardo Sanches has a broad practice that spans anti-corruption, corporate integrity, M&A, regulatory and public law.
With 'deep knowledge of Brazilian anti-corruption law', Machado Meyer Sendacz e Opice Advogados is noted for its 'commitment' and 'discretion to deal with sensitive matters'. The compliance and corporate integrity team has broad experience in internal and government investigations, crisis management and risk assessments. The firm was retained by a multinational company to review its internal compliance program and provide comprehensive anti-corruption training to employees in several locations throughout Brazil. Marcos Paulo Veríssimo heads the department, which includes recommended senior associates Gabriela Viana and Raphael Soré.
Peixoto e Cury Advogados
Peixoto e Cury Advogados advises clients on anti-corruption legislation, crisis management, leniency agreements and ethical conduct programs. The firm has a long history in the market and several of its clients are longstanding, though it also attracts instructions from new clients. In a major highlight, the team represented a foreign company in the execution of a leniency agreement with multiple public authorities; Pedro Jorge da Costa Nassar Cury, José Ricardo de Bastos Martins and Renato de Oliveira Valença were the lead lawyers.
The anti-corruption and compliance group at Tauil & Chequer Advogados in association with Mayer Brown is led by Luís Inácio Lucena Adams, who draws on almost 24 years of experience in public service, including as Attorney-General of Brazil between 2009 and 2016. He works alongside Michel Sancovski to represent the firm's multinational and domestic clients in internal investigations, leniency agreements and administrative enforcement. Associate Maria Eugenia Kanazawa is another key contact; she balances a varied workload including corporate investigations, compliance and tax.
Heloísa Barroso Uelze leads the compliance practice at Trench Rossi Watanabe, which is equipped to handle large and sensitive investigations. Much of its work is cross-border in nature; in one highlight, the team acted for a company in a multi-jurisdictional investigation into potential violations of anti-corruption laws; it continues to assist the client with demands from Brazilian and international enforcement authorities.