Compliance in Brazil
Azevedo Sette Advogados has solidified its leading position in this market segment following the hires of Isabel Franco and Glaucia Ferreira in May 2019. Covering the gamut of anti-corruption and compliance work, the firm is a popular choice for multinational companies operating in a broad range of sectors. Also of note in the team are Luiz Eduardo Salles, whose broad practices encompasses economic law and anti-corruption, and senior associates Ingrid Bandeira Santos and Lucas Bianchini, who often work on the department's key cases.
Localiza Rent a Car
FujiFilm Holdings America Corporation
LATAM Airlines Group
Santo Antonio Energia
American Tower Corporation
- Continued to assist LATAM Airlines Group with the monitoring imposed by the US Department of Justice and the US Securities & Exchange Commission in light of the Deferred Prosecution Agreement executed by LATAM.
- Retained by Santo Antonio Energia with an exclusive contract to conduct several integrity due diligence reports regarding certain third parties relating to the client.
- Assisted a major Brazilian company in an investigation of a complaint of bullying and sexual harassment involving individuals in key positions.
- Assisted Localiza Rent a Car with anti-corruption and compliance due diligence.
Demarest Advogados strengthened its compliance practice considerably with the December 2019 hire of Eloy Rizzo Neto from KLA Advogados; Rizzo 'always puts the client as a priority, facing the project challenges and solving the problems in a smart and kind way'. He joined Carlo Verona, who has strong experience in investigations involving issues related to the FCPA, UK Bribery Act and international enforcement. On the preventive side, the team advises on compliance programmes, training and integrity due diligence. The team also draws as required on the input and expertise of white-collar criminal law expert Fabyola En Rodrigues and competition specialist Bruno Drago.
‘Demarest has the whole package. The compliance team delivers the same high-quality results for both internal investigation and consultancy works (third party due diligence and compliance risk analysis). The team is always available and I truly feel my company needs are a priority even though the firm has so many other clients.‘
‘Demarest has a very committed, qualified and experienced team providing compliance services. I’ve been working along its team for five years and in my perspective they are some steps ahead in comparison with other law firms in terms of offering customised solutions to the clients.’
‘The team is always available, including alternative hours and private cell phones. It is a senior team, with an excellent knowledge of compliance matters, they also understand the company’s daily routine, so it is not pro forma knowledge. They stick to what is really necessary.‘
‘Eloy is excellent. He knows Brazilian, EUA and Europe laws. He understand the reality here in Brazil and pushes when its needed. He is objective and always available, I have had may cases conducted by him and he is the first lawyer that I think when I have an issue or need some advice.’
‘Eloy has a great balanced view of compliance risks and understands the business reality of taking risks. Victoria delivers 100% and I would like to have her for every complex internal investigation. André is attentive and detailed when performing compliance risk analyses.‘
‘My experience is with Eloy Rizzo and his team, who joined Demarest last year. I think highly of Eloy, and I believe Demarest has significantly upgraded its practice by adding Eloy Rizzo.‘
‘I think one of the things that makes Eloy Rizzo stand out is his ability to work as part of a team. Most of my matters are cross border, and as a result require multiple law firms in multiple countries. Those arrangements can be very difficult. But not with Eloy. He gives great advice, and is a great teammate.’
‘Eloy Rizzo, head of the compliance team has been in charge of many complex projects and his experience makes the difference in all of them. Besides that Eloy has many leadership skills which makes our collaboration in working very effective and transparent. Eloy always put the client as a priority, facing the project challenges and solving the problems in a smart and kind way.‘
Olympic Council of Ireland Executive Committee
Camargo Correa Infra Projetos
Johnson & Johnson
Johnson & Johnson
- Retained by EcoRodovias to provide legal and compliance advice in connection with its independent monitorship.
- Retained by CBMM to perform integrity due diligence reports regarding each of the company’s new suppliers.
- Provided anti-corruption training sessions to Multiplan’s main executives.
- Retained by Fujifilm to perform integrity due diligence reports regarding each of the company’s new suppliers.
The 'well-knit team of compliance specialists' at Saud Advogados are 'extremely results-driven and focused on the clients' needs'. It is well versed in compliance, investigations and enforcement proceedings, and benefits from its cooperation with Hughes Hubbard & Reed LLP. The majority of its lawyers are based in Rio de Janeiro, though the firm recently established an office in São Paulo. Practice head Salim Jorge Saud Neto has a well-established reputation among the leading practitioners in the field of compliance in Brazil. Caroline Rosa and Ana Carolina Chaves are key contacts at the associate level. Bernardo Viana left the firm in 2020.
‘The main strength is its qualification about compliance. Many firms have several specialities and, among others, compliance. Saud Advogados is a compliance firm. In addition, it’s a down to earth firm in terms on approach to companies and on how to dialogue with non-lawyers.’
‘Salim Saud leads a well-knit team of compliance specialists who are able to demonstrate their deep knowledge on ABC matters.‘
‘Salim Saud has an amazing capability to understand concerns, picture scenarios and communicate on an easy way.’
‘Saud Advogados has the gift to understand the needs of the client and are extremely results-driven and focused on the clients’ needs. A small boutique aimed at dealing with all aspects of anti-corruption compliance.‘
‘Besides the expertise of the law firm, mainly of Mr. Salim Saud, I would say their strengths are the level of professionalism in terms of communication, day to day availability for their clients (yes, each one feels unique), deliverables, response timing and quality of work product.‘
‘Salim Saud is the name for compliance in Brazil. Very updated with the current trends and always available.’
Souza Cruz (BAT)
Mubadala Development Company
Helix Energy Group Solutions
- Assisted TechnipFMC in a global settlement involving numerous Brazilian and US authorities.
- Assisted Souza Cruz with: a compliance risk assessment; an assessment of the company’s compliance programme in light of Brazilian and UK legislation; training in compliance matters and internal policies; consultancy on compliance in data protection; and consultancy in sanctions regulations.
- Assisted Stago with the tropicalisation of its global compliance programme in light of recent Brazilian anti-corruption and data privacy legislation.
- Assists Kering Group in the tropicalisation and implementation of an anti-money laundering policy in light of Brazilian regulations, as well as in anti-bribery and corruption compliance matters.
TozziniFreire Advogados stands out for its long track record in compliance in Brazil, and clients praise the fact that the 'partners are always directly involved in the cases, and demonstrate full knowledge of the matter and its details'. It has the size and resources to handle complex cross-border investigations and is entrusted by household name companies in sensitive matters. Well-known compliance specialist Shin Jae Kim leads the team, which includes internal investigations and regulatory and criminal enforcement specialist Karla Lini Maeji; Giovanni Paolo Falcetta, who advises on compliance risk analysis and internal investigations related to fraud, corruption and violation of internal policies; and Renata Muzzi Gomes de Almeida, who has a broad compliance practice and 'is always available to hear and understand the client's needs'.
‘I believe TozziniFreire has been one of the key players in the compliance area, with very active partners, with deep legal knowledge and good relationships with authorities. Their partners are always directly involved in the cases, and demonstrate full knowledge of the matter and its details. Very well structured approach and presentation of the work done.’
‘Highly skilled partners, with lots of experience in dealing with the authorities, very thorough in their analysis, very good case presentation skills, easy to work with.’
‘TozziniFreire is the main firm on this practice in Brazil by a good distance.‘
‘They had a large team and therefore could deal with many assignments at the same time varying from third-party due diligence, policy drafting and internal investigation to annual risk assessment. Because Tozzini is a full-service law firm, if any situation required a second opinion with a more specialized lawyer, they could promptly provide such advice.‘
‘Renata Muzzi is always available to hear and understand the client’s needs. She was crucial for Tozzini’s taking into consideration the business, the market, and the company’s reality into their legal opinion.’
‘Karla Lini Maeji, Tozzini’s compliance partner, is really a business partner, providing outstanding support, with innovative thinking while always providing guidance in a legally compliant manner. Karla is also able to build a healthy relationship with the company’s stakeholders, providing an environment of trust between the company and the firm.‘
‘TozziniFreire compliance team is unique as they can perform a deep compliance investigation without causing useless harm. As a firm with specialists in the various areas of law they can cover all aspects of the investigation. As a consequence, a real effective investigation is made coming to a correct conclusion.’
- Conducted an extensive internal investigation in a pharma company triggered by a government investigation.
- Conducting an extensive internal investigation in one of the biggest food companies in the world, linked to a governmental investigation.
Mattos Filho, Veiga Filho, Marrey Jr. e Quiroga Advogados is noted for its 'highly-qualified professionals' and 'sophisticated view and practical approach'. Multinational companies, many of which are leaders in their respective fields, turn to the team for advice and representation on internal investigations, leniency negotiations and compliance due diligence. Key names in the sizeable team include Thiago Jabor Pinheiro, Thiago Luís Sombra, Renato Tastardi Portella, Kevin Michael Altit and associate Luiza Mussoi Cattley.
‘They have highly qualified professionals in the team, like Thiago Jabor, and some people who have been working in the field for a while, like Renato Portella. Because of this combination, they can have, at the same time, a sophisticated view and a practical approach. In other firms, typically, compliance areas area being formed with people who move from other practices.‘
‘Thiago Jabor, highly qualified, a top professional, who understands the needs of the client and has all the tools to solve the most complex problems.’
‘Renato Portella is practical and has a broad experience, being able to settle things down in the middle of a turmoil.‘
Dolce & Gabbanna
Proparco – Groupe Agence Française de Développement
Mitsui & Co
- Represented Keppel to reach a global resolution agreement with Brazilian and international authorities, and continues to advise the company in connection with the performance of leniency agreement obligations.
- Retained by the Recovery Committee of Vale to provide legal advice in connection with the failure of Dam I of the Córrego do Feijão iron ore mine in Brumadinho.
- Represented a multinational company in conducting internal investigations and remediation measures in connection with potential fraud and other misconduct at the group’s Brazilian subsidiary.
The highly regarded compliance team at Pinheiro Neto Advogados handles a range of preventive and enforcement work and has recently been particularly active in anti-bribery investigations. Its team has multi-disciplinary expertise in litigation, compliance, white-collar criminal law, antitrust and public law. José Alexandre Buaiz Neto, Mário Panseri Ferreira and Ricardo Pagliari Levy are key names in São Paulo; Vicente Coelho Araujo and Daniel Costa Rebello - who made partner in January 2020 - are based in Brasília.
Caixa Econômica Federal
- Represented SBM Offshore in the internal investigation and subsequent execution of two agreements with the Brazilian authorities in charge of anti-bribery investigations.
- Performed an extensive investigation into Caixa Econômica Federal, the largest public bank in Latin America.
- Assisting TÜV SÜD with its internal investigation into the certification of tailing dams in connection with the Brumadinho dam collapse that occurred in January 2019.
The compliance department at Tauil & Chequer Advogados in association with Mayer Brown is particularly active in internal investigations, and also represents clients in administrative proceedings and supports the corporate practice in due diligence processes. Michel Sancovski in São Paulo is noted for his 'good persuasion and negotiation skills'. Brasília-based Luis Inácio Lucena Adams has strong experience in the field of compliance and draws on previous experience as Attorney General of Brazil. The department also benefits from the input of a number of experienced associates, including Maria Eugenia Kanazawa and Liliana Coutinho.
‘Tauil & Chequer has been growing a lot in Brazil, through the acquisition of high profile partners from several areas of expertise. Its association with Mayer Brown puts them in a differentiated position in the market, as they can rapidly and seamlessly bring together their skilled professionals from both the US and Brazil.‘
‘Michel Sancovski: Very solid professional, good in dealing with clients and good persuasion and negotiation skills.‘
‘The partner responsible for the team is highly competent but it was even better to see that competence was also in the team. Everyone was ready to support, responses were fast the different work streams very well integrated.‘
‘The firm was able to quickly support on our requests and to overcome concerns during the process. They were also well updated on similar cases in the market in order to provide good understanding of local impacts.‘
Companhia Paranaense De Energia (Copel)
Vantage Drilling International
Caisse de depot et placement du Quebec (CDPQ)
Primav Construções e Comércio (EcoRodovias)
Wells Fargo Bank
- Conducting a large internal investigation of potential irregularities related to a client’s subsidiaries.
- Provided legal advice to Vantage Drilling International (VDI) in an administrative improbity lawsuit filed by the Brazilian Government against VDI and others in the context of Operation Car Wash.
- Advised a client in connection with the negotiation of a leniency agreement with the Federal Prosecutor’s Office.
Anna Carolina Malta and José Guilherme Berman head BMA - Barbosa, Müssnich, Aragão's 'highly skilled team', which adopts a multi-disciplinary approach to assist clients in all aspects of compliance matters, including prevention, investigation and remediation. Recent work includes advising on compliance programmes, due diligence, internal investigations and administrative improbity proceedings. Camila Cuschnir is another name to note.
‘Highly skilled team, very concerned with meeting the clients objectives and demands.‘
‘Excellent relationship, easy to work with, very good in transmitting their knowledge.’
Carioca Christiani-Nielsen Engenharia
Grupo Águas do Brasil (SAAB)
Engie Brasil Energia
Neoenergia (Iberdrola Group)
Multiplan Empreendimentos Imobiliários
Lanxess Indústria de Produtos Químicos e Plásticos
- Provided a company and its executives with training on moral and sexual harassment.
- Assisted Engie Brasil Energia with the integrity due diligence of Transportadora Associada de Gás (TAG), a Petrobras asset.
Campos Mello Advogados in cooperation with DLA Piper's compliance team acts for a number of well-known international clients, and benefits from the firm's cooperation agreement with DLA Piper. Its recent workload includes compliance audits, compliance due diligence and internal investigations. Practice head Ricardo Caiado Lima - who was promoted to partner in June 2019 - and senior associate Ana Júlia Andrade Vaz de Lima are the key contacts.
‘We are very happy with the good services provided to us by the compliance team of Campos Mello Advogados.’
‘Very good, independent and transparent team. Are able to handle complex situations with a very good approach.’
‘Though the compliance team is young, the lawyers have a deep knowledge of the area and are quick to understand the internal structure of our business and the business of a target, which makes the investigative approach much more efficient.’
‘Ricardo Lima is the one individual I would mention, not only for his technical capabilities, but also for his humbleness and adaptability to deal with hard and complex situations.’
‘Transparency and clear communication.’
‘We could see the huge difference working with Campos Mello, being 100% ethical and transparent during the whole process.‘
‘The individuals that usually take care of our needs in the compliance area are Ricardo Caiado Lima (partner) and Ana Julia Andrade Vaz (lawyer). Both are very competent and always respond to our demands on a timely basis.’
Cescon, Barrieu, Flesch & Barreto Advogados is noted for having a 'very good blend of antitrust, government relations and criminal lawyers working together in the practice'. In recent developments, white-collar criminal law specialist Yuri Sahione joined from his former boutique firm. He and co-practice head Luciano Inácio de Souza handle a range of compliance consultancy and investigations work.
‘Cescon was one of the first Brazilian firms to understand that compliance work should be connected to other practices. They have a very good blend of antitrust, government relations, criminal lawyers working together in the practice.‘
‘Luciano Inácio de Souza – he has a great government relations background and know all the nuances of Brasilia. He is very good with clients on public-private dialogue. Luciano Inácio de Souza also has tremendous experience on compliance training for multinationals. Ricardo Gaillard and Joyce Honda – fantastic competition lawyers with a heavy compliance component. The three of them are great in promoting client development initiatives and we also have efforts together in this sense.‘
Copagaz Distribuidora de Gás
HalexIstar Indústria Farmacêutica
World Wildlife Fund – WWF
Localiza Alugue um Carro
Alibaba Group (Alipay)
- Assisting a pharma company with conducting a full risk assessment of the company and creating and implementing an effective compliance programme, including the creation of new policies and internal controls.
- Assisted global NGO World Wildlife Fund (WWF) with developing its compliance programme in Brazil in accordance with the requirements of the Brazilian Clean Company Act and other related legislation.
Dias Carneiro Advogados continues to handle a significant number of internal investigations and also advises clients on crisis management, compliance programmes and compliance in the context of public bids. Practice head Joyce Ruiz Rodrigues Alves is 'an excellent advisor on compliance matters'. André de Melo Ribeiro and counsel Andrea de Sousa Machado are also active members of the team.
‘Partner availability and involvement is remarkable. The quality of work delivery is really consistent.‘
‘Joyce Alves is an excellent advisor on compliance matters. She has a lot of experience and practice on the field. She is a partner always available for her clients and gets personally involved in the work. Her team is well trained and occasional changes are smooth to clients.‘
Ciena Communications Brasil
CIFI – Corporacion Interamericana para el Financiamento de Infraestrutura
Companhia Melhoramentos de São Paulo
Cristália Produtos Químicos Farmacêuticos
GLP Brasil Empreendimentos e Participações
Inter American Development Bank (IDB)
Full Truck Alliance
- Representing companies from Servizi Group in an administrative proceeding relating to non-compliance with Brazilian anticorruption legislation.
- Assisting a company in the pharma sector with a number of investigations carried out by Brazilian authorities regarding alleged anti-corruption and antitrust violations.
KLA Advogados' compliance practice endured significant departures in 2019, most recently that of Eloy Rizzo, who moved to Demarest Advogados in December. Nevertheless, the team continues to handle a range of sensitive investigations, integrity due diligence processes and compliance training; white-collar criminal law expert Filipe Magliarelli and Catarina Rattes - who can draw on previous in-house experience, including in a Big Four accounting firm - now co-lead the department.
Machado Meyer Sendacz e Opice Advogados counts leading domestic and international companies among clients it assists with investigations, compliance due diligence processes and leniency agreement negotiations. Key practitioner Marcos Paulo Veríssimo has strong knowledge of anti-corruption, crisis management, compliance and competition law. The firm also bolstered its white-collar criminal defence offering with the June-2019 hire of Juliana Sá de Miranda from Campos Mello Advogados in cooperation with DLA Piper. Associate Gabriela Silveira Viana is another key member of the practice group.
‘Gabriela Viana is a very talented attorney with great client support skills and does seem to have above average capability to put herself in client’s shoes.’
Scania do Brasil
Brunswick Corporation (Mercury Marine)
- Advised SoftBank on the anti-corruption perspective of its investment in a Brazilian online platform for home goods.
- Assisted a client with the elaboration of a structured whistle-blower channel.
The compliance and ethics department at Peixoto e Cury Advogados advises clients on corporate ethics, compliance programmes and compliance management. José Ricardo de Bastos Martins acts as a member of the Independent Oversight Committee created to monitor and supervise all the obligations provided for in the non–prosecution agreement executed between J&F Investimentos and the Federal Public Prosecutor’s Office. Compliance and corporate law expert Renato de Oliveira Valença co-leads the team.
‘Capable and fast to analyse issues and come up with solutions.’
Allfood Importação, Indústria e Comércio
American Air Filter Brasil
Bbrands Holding Participações
Cebrace Cristal Plano
Cecil – Laminação de Metais
China Three Gorges Corp (CTG Brasil)
CServices Processamento de Dados
FCB Brasil Publicidade
Knauf Do Brasil
McCann Erickson Publicidade
Mullen Lowe Publicidade
MSA do Brasil Equipamentos e Instrumentos Segurança
Owens-Illinois do Brasil Indústria e Comércio
Sparkinc Mídia de Influência
The Interpublic Group of Companies
Vleaf Energia e Engenharia
- Acts as a member of the Independent Oversight Committee created following the non–prosecution agreement between J&F Investimentos and the Federal Public Prosecutor’s Office.
- Provided training to a client’s attorneys in connection with Brazilian anti-corruption legislation.
Trench Rossi Watanabe
The 'very responsive' compliance team at Trench Rossi Watanabe is noted for its 'reliable advice'. Household international companies turn to the firm - which has a long track record in advising on anti-corruption and FCPA cases - for advice on compliance risk assessments, codes of conduct, internal investigations and training. Heloísa Barroso Uelze and Felipe Ferenzini are the key names.
‘The team has a great understading of our business, being able to present timely and creative, feasible solutions that meet our business necessities. This is, maybe, one of the greatest accomplishments of a team we are willing to work with.’
‘The team has great experience with compliance matters and the possibility of building bridges between Brazilian and USA law/requirements.‘
‘I think the team, which counts Heloisa Uelze and Felipe Ferenzini, the two people with whom I have worked closely, is a PERFECT balance of a mature and seasoned lawyer (Heloisa) who has navigated public and private areas of law with extreme competence and success for more than 20 years now and Felipe, who is of a younger generation and can bring to the team innovative solutions. This is important, because compliance issues speak directly to the culture of a company. So, they can attend a public company, a multinational or a start up, bringing that necessary balance of tradition and modernity.’
‘For many years now Trench Rossi has provided our firm with reliable advice and guidance on a wide range of issues from regulatory matters to public procurement to litigation. They are very responsive and their advice is reliable and practical.’
‘Their fees have been reasonable and they do a good job of not “over-lawyering” – which can quickly result in high fees on matters that do not necessarily warrant many hours of billable time.’
‘Felipe Ferenzini is always my “go-to” lawyer at the firm whenever I need help on a legal issue in Brazil. When there is a matter that is outside his area of expertise, he quickly assembles an appropriate team from his firm to assist. Lately we have been working with Felipe on regulatory matters in Brazil and have also appreciated both his and his colleague Gabriela Paiva-Morette’s guidance on these matters.‘
- Assisting Samsung with improving and monitoring internal compliance measures, including designing policies and business models.
- Advised Wiz Soluções on compliance due diligence in connection with its acquisition of Barigui Corretora.
Veirano Advogados' 'dedicated team' has a strong orientation towards investigations, where it acts for clients in the healthcare, construction and financial services sectors, among others. The team is led by Mariana Villela in Rio de Janeiro and Rafael Gimenes in São Paulo and also advises clients on internal policies and compliance due diligence.
‘Dedicated team and very committed to the services provided, with always useful and effective suggestions and quick and thorough responses to all demands.‘
‘The team in Veirano has strong knowledge in the area.’
‘Services provided with extreme quality, with lawyers always very diligent and committed to the urgency of certain demands. The lawyers contribute with a lot of quality to the company’s business and meet short demands of high complexity.’
Miriam Minas Automoveis
Turismo Três Amigos
The Nature Conservancy Brazil
- Advising a well-known company in internal investigations.
- Assisted a company in the transport sector with a comprehensive compliance programme and a review of its business practices.
The highly regarded team at Warde Advogados handles a range of preventive compliance work and administrative proceedings. Practice head Valdir Moysés Simão has significant past experience in the public sector coupled with broad knowledge of compliance, investigations, government enforcement, administrative proceedings, leniency agreements and corporate ethics. Leandro Daiello Coimbra has a background in the federal police force and specialises in internal investigations.
‘The Warde team has a great experience working at the regulatory branches in Brazil.’
‘The partner Valdir Simão has a unique experience in dealing with Controladoria Geral da União.’
M Dias Branco Indústria e Comércio de Alimentos
Santo Antônio Energia
- Advised a client in the context of an independent internal investigation.
- Representing the interests of a company in the execution of a leniency agreement, under which it will pay around R$1.4bn to the treasury.