Brazil

The move will help expand their joint national presence, strengthening their full‑service capabilities in high‑complexity transactions and disputes.   São Paulo, March 23, 2026 – Madrona Advogados and Coelho & Dalle announce this Monday (03/23) a strategic alliance, under which Coelho & Dalle will operate under the “Madrona Advogados” brand, from São Paulo, Belo Horizonte, Fortaleza, and Recife. This move follows the successful association with Fialho Salles in 2023.   The initiative will reinforce full‑service legal counsel for domestic and international clients in high‑complexity strategic transactions and disputes, as well as strengthen their practice areas and industry capabilities. In addition, the alliance will bring them both closer to their clients while preserving regional characteristics, maintaining local presence and the relationships built in each market. Clients will benefit from complementary expertise and more robust practice areas, while retaining agile, business‑oriented strategic service.   In recent years, Madrona Advogados has been consolidating its governance structure, focusing on efficiency and raising delivery standards for clients, combining seamless, straightforward interactions with clients and partners, with high performance and close, excellence‑driven service. Today, the alliance brings together 44 partners and 131 associates, distributed across more than 20 practices.   Coelho & Dalle Advogados also provides full‑service legal counsel, with a team of 89 professionals — including four partners and 66 technical staff — working across the main areas of law. Over the years, it has stood out for its performance grounded in technical rigor, responsiveness, and detailed understanding of each client’s business, both in the Northeast, where it began, and from its São Paulo office, which expanded its operations in 2014.   “This closer relationship between the teams was built over roughly a year of conversations and joint work. It was a process that gradually strengthened the trust among all of us. We also identified a strong alignment in values and culture regarding the practice of law, client service with technical excellence, and caring for our people and our social responsibility,” says Danilo Mininel, CEO of Madrona Advogados.   For Coelho & Dalle, the alliance represents an important step in its institutional trajectory. “The association with Madrona Advogados increases our competitive capacity and strengthens our work in significant business matters and disputes in the legal market, while absorbing consolidated learning, know‑how, and credibility. We expect not only to accelerate the strategic objectives the firm had already been pursuing, but also to expand our national recognition,” says partner Eduardo Coelho.   About Madrona Advogados Madrona Advogados is a full-service legal practice recognized for combining excellence with agility to deliver precise and effective solutions for complex projects, with 44 partners and nearly 300 professionals specialized across administrative law and a wide range of practice areas. According to TTR Brasil’s 2024 Annual Report, Madrona Advogados ranks among Brazil’s top ten practices in merger and acquisition (M&A) transactions. Over the years, it has been consistently recognized by leading international legal directories and publications, including Chambers Brazil (Elite in M&A), Chambers Global, The Legal 500, Latin Lawyer 250 (LL250), LACCA Approved, Leaders League, IFLR1000, Who’s Who Legal, Análise Advocacia 500, Análise Advocacia, and Mulher.   About Coelho & Dalle Founded in 2007, with a solid trajectory in the legal market of the Brazilian Northeast, Coelho & Dalle is a full‑service law firm that works closely and strategically with its clients, seeking to deeply understand each matter to build consistent and effective legal solutions. The firm combines rigorous technical analysis with direct and individualized case handling, prioritizing long‑term relationships and an approach focused on solving complex problems with clarity and efficiency. With offices in Recife, São Paulo, and Fortaleza, it is ranked by Great Place to Work – GPTW and by legal directories such as Chambers & Partners, IFLR1000, The Legal 500, Latin Lawyer, ITR World Tax, LACCA Approved, and Leaders League.   Press contact  InPress Porter Novelli   Juliano Wladimir Capato +55 11 99260-5446 [email protected]   Alexandre Carvalho +55 11 99329-0909 [email protected]

The move strengthens the firm’s strategy to expand its work in complex transactions and strategic tax planning. São Paulo, March 19, 2026 – Madrona Advogados announces the arrival of Roberto Salles as a new partner in its Tax practice. With three decades dedicated to Tax and Fiscal Law, Roberto has built a career marked by his work in international transactions, tax structuring for mergers and acquisitions, and leadership of complex, multidisciplinary projects for both domestic and international clients.   Before joining Madrona Advogados, Roberto was a partner in the International Tax practice at KPMG Brazil, where he focused on Pillar 2, international transactions, tax‑structuring strategies, and strategic projects involving corporate reorganizations and M&A transactions. Previously, he was a founding partner of Fialho Salles Advogados, where he led the Tax and Fiscal Law practice, advising companies from various industry sectors on complex and high‑impact tax matters.   Recognized by publications and legal directories, Roberto has been featured in rankings such as Análise Advocacia 500, The Legal 500, and Chambers and Partners. Throughout his career, he has developed strong expertise in tax planning, international taxation, tax structuring for investments, and strategic support for major corporate transactions.   “Roberto Salles’ arrival represents a strategic reinforcement for our tax team. His experience in international transactions, tax structuring for mergers and acquisitions, and leadership in complex projects adds even greater technical depth to our already highly experienced team. We are confident that his strategic vision and ability to handle high‑complexity matters will further strengthen our work and generate value for our clients,” says Danilo Mininel, CEO of Madrona Advogados.   “This is an opportunity to join a team of outstanding technical excellence, with a strong commitment to collaboration, innovation, and ethics. My goal is to contribute my experience and support clients and partners by adding expertise in international taxation and advancing a legal approach to Pillar 2—a new and challenging topic for multinational companies, and one I have been involved with since the beginning,” Salles notes. With this appointment, Madrona Advogados strengthens its tax team and expands its ability to advise clients on strategic tax matters and high‑complexity transactions, reaffirming its commitment to technical quality, strategic vision, and value generation.   About Madrona Advogados Madrona Advogados is a full-service legal practice recognized for combining excellence with agility to deliver precise and effective solutions for complex projects, with 44 partners and nearly 300 professionals specialized across administrative law and a wide range of practice areas. According to TTR Brasil’s 2024 Annual Report, Madrona Advogados ranks among Brazil’s top ten practices in merger and acquisition (M&A) transactions. Over the years, it has been consistently recognized by leading international legal directories and publications, including Chambers Brazil (Elite in M&A), Chambers Global, The Legal 500, Latin Lawyer 250 (LL250), LACCA Approved, Leaders League, IFLR1000, Who’s Who Legal, Análise Advocacia 500, Análise Advocacia, and Mulher.   Press Contact InPress Porter Novelli Alexandre Carvalho +55 11 99329-0909 [email protected]    

The evolution of the regulatory environment in the insurance market has required entities supervised by the Superintendence of Private Insurance ("SUSEP") to demonstrate greater institutional maturity, governance, and regulatory compliance. In this context, the entry into force, in January 2026, of the new sanctioning regime established by Complementary Law No. 213/2025 ("LC 213/2025") raised the level of regulatory scrutiny and compliance expectations imposed on supervised entities. LC 213/2025 strengthens SUSEP's authority by expanding its sanctioning powers and reorganizing the administrative process, introducing greater severity in sanctions and reinforcing the accountability of legal entities and their administrators. From the perspective of anti-money laundering and counter-terrorism financing ("AML/CFT"), this new scenario underscores the need for full adherence by supervised entities to consolidated regulations, as well as the implementation of compliance programs aligned with applicable legislation and best practices. Therefore, structured compliance policies and procedures plays a relevant role in supporting supervised entities in assessing and strengthening their governance and risk management frameworks. This article aims to analyze the expansion of the new SUSEP sanctioning regime vis-à-vis its connection with AML/CFT regulatory frameworks, as well as to highlight the strategic relevance of the compliance program in this scenario. New SUSEP sanctioning regime LC 213/2025 redefines the treatment of regulatory infractions, strengthening the sanctioning regime and expanding the instruments available to SUSEP. Amongst the greatest changes for supervised entities, the following stand out: (i) the increase of 3,500% in fines, which may now reach BRL 35,000,000.00 (thirty-five million reais), with dosimetry criteria that consider the contract value, the damage caused and the economic advantage obtained; (ii) the express provision of coercive fines; (iii) the aggravation of sanctions in case of recidivism, with fines up to three times the limit of BRL 35,000,000.00 (thirty-five million reais); (iv) the imposition of joint liability to directors, administrators, managers and auditors of supervised entities, for damages caused to third parties, including shareholders; and (v) for individuals, disqualification penalties ranging from 2 (two) to 20 (twenty) years for holding positions or functions in the public or private sector. It is worth noting that sanctions may be applied either individually or cumulatively, thereby broadening SUSEP’s discretionary margin in holding supervised entities accountable. As a result, entities operating in the insurance sector are increasingly required to reassess the robustness of their governance structures, internal controls, and compliance monitoring mechanisms. Changes under the AML/CFT perspective and compliance programs as a strategic instrument The new regime directly dialogues with SUSEP Circular No. 612/2020, which establishes minimum requirements for the development and implementation of policies, procedures, and internal controls related to AML/CFT, in accordance with the nature, complexity, and risks of each entity's operations. This dialogue is consolidated as the new regime intensifies the sanctioning framework applicable to non-compliance with AML/CFT obligations, resulting in greater urgency for the effective adherence of supervised entities to applicable rules. It is important to emphasize that mere formal regulatory compliance is not sufficient. Ensuring the practical effectiveness of AML/CFT instruments is key, so that they translate into efficient operational mechanisms. In this context, an effective compliance program goes beyond preventing irregularities, serving also as a mitigating instrument in cases of non-compliance. To this end, it must be structured through periodic risk assessments that guide the proper implementation and updating of internal policies and procedures, including regular training, thereby strengthening internal controls. Beyond a regulatory obligation, compliance programs should no longer be viewed solely as regulatory requirements, but as strategic governance tools capable of mitigating enforcement risks and demonstrating regulatory maturity before supervisory authorities. It enables supervised entities to safeguard themselves under the new sanctioning regime, preserve their reputation, and consolidate their position in an increasingly demanding regulatory environment attentive to the effectiveness of compliance with applicable standards. Conclusion LC 213/2025 starts a new sanctioning paradigm within SUSEP’s supervisory framework, characterized by greater rigor, extension, and sophistication of accountability instruments. This new scenario shifts the axis of compliance from a merely formal approach to a more substantive one, oriented toward the effectiveness of supervised entities’ controls and policies, as well as a strategic and proactive posture, with emphasis on AML/CFT obligations. In response to this evolving regulatory landscape, insurance companies and financial groups have increasingly prioritized the review of their AML/CFT governance structures and internal controls. In this context, the adoption of robust, structured, and continuously evaluated compliance programs ceases to be merely a regulatory requirement and consolidates itself as a central element in risk management and institutional protection. Given this scenario, it is increasingly common for supervised entities to consider the use of specialized external technical support, complementing their internal structures, particularly in processes of diagnosis, review, and enhancement of compliance and AML/CFT programs. Therefore, the effectiveness of controls and governance becomes a strategic element in the insurance market. The ability of supervised entities to demonstrate robust governance structures and effective compliance frameworks will be decisive not only for mitigating regulatory exposure, but also for accessing new business opportunities, ensuring the sustainable expansion of their operations, and strengthening their competitive position in the long term. Our firm advises domestic and international clients on AML/CFT frameworks and compliance investigations. Authors: Salim Saud, Caroline Rosa, Leonardo Kozlowski.

Legal databases, investigative tools and the role of the Public Prosecution Service in the digital age Fábio Medina Osório Lawyer · Former Minister of the Attorney General’s Office · Former Public Prosecutor in Rio Grande do Sul · Doctor of Administrative Law from the Complutense University of Madrid Abstract This article examines the liability of public and private agents in the face of the advancement of artificial intelligence, focusing on three central axes: (i) the fundamental right to comprehension as a constitutional requirement of algorithmic auditability and integration of legal databases; (ii) the technological tools of criminal investigation available in the Brazilian legal order and their underutilisation; and (iii) the strategic role of the Public Prosecution Service in the construction of a public security policy based on data, qualified statistics and artificial intelligence. It is argued that the digital age imposes a profound institutional reconfiguration, particularly upon the Public Prosecution Service, which holds investigatory powers and must assume leadership in the parameterisation of national public security. Keywords: Artificial intelligence; liability of public agents; legal databases; Public Prosecution Service; criminal investigation; public security; algorithmic auditability. 1. Introduction We are living through a historic moment of inflection. Artificial intelligence is no longer an emerging or peripheral phenomenon to Law: it already forms part of judicial decisions, criminal investigations, administrative contracts and public policies. This article systematises reflections on the responsibilities that arise from this new paradigm, with the aim of contributing to the legal debate surrounding artificial intelligence, databases and the institutional reform required of the Public Prosecution Service. The central proposition is that the integration of legal databases, statistics and artificial intelligence is not merely a technological convenience, but a constitutional requirement derived from the principles of transparency, publicity, due process of law and the controllability of public acts. Without such integration, any theory — be it neo-constitutionalism, new originalism or post-structuralism — remains an inert abstraction in the face of the decisional opacity that plagues Brazilian institutions. 2. The Fundamental Right to Comprehension and Algorithmic Auditability The Federal Constitution of 1988 enshrines, in systematic conjunction, the rights to transparency, publicity and due process of law. From an integrated reading of these fundamental rights it is possible to derive a right to comprehension of the decisions of public authorities — a right that, in the age of artificial intelligence, assumes even more essential contours. This fundamental right to comprehension requires that all decisions of public authorities — not only judicial ones, but also administrative acts, public contracts, administrative jurisprudence and disciplinary proceedings — be supported by legal databases integrated with statistics and auditable artificial intelligence. Auditability is not an adjective; it is a condition of validity. Without such statistical traceability, no decision-making system — regardless of the legal theory informing it — is able to detect biases, anti-isonomy distortions or structural prejudices. Decisional coherence is not a matter of theoretical purity: it is a matter of verifiable equality. An identical case, decided with distinct parameters and without traceable justification, violates the principle of equality in a way that no dogmatics can repair without data. It is further submitted that this right to comprehension has a universal vocation, being applicable not only to judicial decisions, but also to universities, legal education, the private sector with a public function and to the totality of acts of federal entities. The integration of statistics, databases and artificial intelligence is, equally, the adequate mechanism for regulating privacy rights and giving normative density to the General Data Protection Law in the public sphere. 3. Technological Tools of Criminal Investigation: State of the Art and Prospects for Use in Brazil 3.1 The Legal Framework: ADPF 1143 and the Absence of a Judicial Prohibition ADPF 1143, reported by Justice Alexandre de Moraes, was brought by the Attorney General’s Office challenging artificial intelligence tools acquired by the Brazilian State for use in criminal investigations. The action alleged the absence of specific regulation for such instruments. However, the Supreme Federal Tribunal did not grant an injunction suspending their use, which means that, in the light of the principle of legality and the principle of juridicity, these tools remain available for use subject to duly reasoned judicial authorisation. This observation is relevant because it reveals a paradox: the Brazilian State acquired investigative instruments of high technological sophistication which, due to institutional underutilisation or insufficient capacity-building, remain largely idle whilst violent organised crime flourishes. 3.2 Remote Access Tools: Capabilities and Constitutional Limits Amongst the tools with the greatest investigative potential, remote access software stands out — of which Pegasus, developed by the NSO Group (Israel), is the best-known example. This is a system that allows the silent and complete invasion of smartphones, with access to messages, e-mails, call history, encrypted files and the covert activation of microphone and camera, transforming the target device into an instrument of environmental surveillance. The use of this type of tool evidently requires robustly reasoned judicial authorisation — mere slight indications are insufficient, nor is the notorious in dubio pro societate, which the jurisprudence of the Supreme Federal Tribunal, in an orientation yet to be superseded, still admits as a parameter for the receipt of charges. The high degree of invasiveness of these tools demands strict proportionality, selectivity in data capture and absolute adherence to the subject matter of the offence under investigation. 3.3 Signal Interception Systems: IMSI Catchers and Mobile Tracking So-called IMSI catchers — devices that simulate legitimate base stations to capture data from mobile devices — represent another category of tool available in the Brazilian investigative arsenal. The PIC-6, for example, is capable of emulating 2G, 3G and 4G telephony stations, capturing the IMSI number of each device (a unique 15-digit identifier), intercepting voice calls and SMS messages and passively tracking users in public or private areas without the need for installed spyware. Complementarily, systems such as the Landmark platform allow continuous location tracking by multiple antennae, with the capacity to monitor up to ten thousand devices per month. Such tools are particularly relevant in operations demanding constant surveillance of targets without direct physical contact — such as investigations into violent criminal organisations, drug trafficking and factions that dominate entire urban territories. 3.4 Undercover Agents and Statistical Tools for Criminal Prediction The Organised Crime Act (Law 12,850/2013) expressly provides for the institution of the undercover agent — a tool enshrined in the most advanced legislation in the world, which allows, under rigorous judicial oversight, the immunity of the agent for the commission of offences in co-authorship with the targets of the investigation. This is a mechanism of high efficacy for penetrating criminal organisations, including their family networks and parallel structures. In the field of statistical and predictive tools, particular mention should be made of Criminalizer (USP), PredPol and the Palantir Gotham platform. These solutions are capable of identifying behavioural patterns, mapping criminal networks and subsidising investigative decisions based on large-scale data analysis. Their efficacy, however, fundamentally depends on the quality and uniformity of the databases that feed them — a central issue examined in the next section. 4. Brazil’s Statistical Deficit and the Reform of Public Security Databases One of the principal structural weaknesses of the Brazilian public security system is the absence of uniformity in criminal databases. Data is fed by the states in a fragmentary manner, with heterogeneous criteria and irregular temporality, making any reliable statistical analysis at the national level impossible. The thesis advanced here is that the National Council of the Public Prosecution Service (CNMP) and the National College of Attorneys General (CNPG) have the competence and legitimacy to regulate public security databases throughout the national territory. The rationale is straightforward: it is the Public Prosecution Service — and not the Federal Executive Power, nor the police authority — that is the holder of the criminal action and the investigatory power. Those who hold the power to investigate equally hold the institutional interest in the quality of the data that feeds such investigation. Regulation by the CNMP and the CNPG should establish, at a minimum: (i) uniform national criteria for the classification and feeding of criminal data; (ii) mandatory frequency of real-time online updates; (iii) integration with the artificial intelligence systems already available; and (iv) mechanisms of external audit and bias control. Without qualified and uniform statistics, the use of artificial intelligence in public security is unviable — the most sophisticated technology cannot correct dirty data. 5. The Public Prosecution Service as a Strategic Actor in the Age of Artificial Intelligence 5.1 The Problem of Deficient Investigations and Premature Charges The recent experience of the Brazilian Public Prosecution Service — particularly in Operation Car Wash and in the investigations into the anti-democratic acts of 8th January 2023 — revealed structural failures that undermine institutional credibility: charges with precarious individualisation of conduct, plea bargains without robust corroborating elements, premature search and seizure warrants and telephone intercepts authorised without the necessary evidentiary support. The jurisprudence of the Supreme Federal Tribunal that admits criminal charges based on in dubio pro societate and mere slight indications is, at one and the same time, constitutionally questionable and institutionally damaging. A premature charge destroys reputations, violates the dignity of the investigated and frequently results in annulled criminal actions — the worst of all worlds for the credibility of the Public Prosecution Service. 5.2 The Model of Exhaustive Investigation The alternative is exhaustive investigation: the Public Prosecution Service must fully utilise the investigatory power at its disposal — including the technological tools described in this article — before bringing any charges. The filing of criminal actions must be guided by a serious prognosis of success and by a robust individualisation of conduct. Success, from this perspective, may take multiple forms: conviction, agreement, archiving or even the decision not to investigate. What is not permissible is the charge as a wager. In this context, the rate of agreements — a modality that in the United States accounts for the overwhelming majority of criminal case closures — must be valued as a measure of efficacy, not as a sign of institutional weakness. Resolutiveness is the true distinguishing mark of the modern Public Prosecution Service. 5.3 The Public Prosecution Service as the Great Law Firm of Brazilian Society There is an illuminating metaphor in the history of the Public Prosecution Service of Rio Grande do Sul: that the Public Prosecution Service is a judge at the doors of the courts. In the age of artificial intelligence, this image must be updated: the Public Prosecution Service must reinvent itself as the great law firm of Brazilian society — with institutional unity, technical capacity, technological instruments and clear leadership over public security data. This also implies rethinking the role of senior prosecutors: not as opinion-writers advising courts, but as protagonists on the front line of the fight against organised crime, in the defence of public assets and in the guarantee of fundamental rights. Institutional fragmentation is the greatest enemy of efficacy. 6. The International Regulation of Artificial Intelligence and the Formation of a New Legal Branch The regulatory landscape of artificial intelligence has been expanding rapidly at the international level. The European Union approved the AI Act; the United States advanced through executive orders on the subject; China and Japan have their own regulatory frameworks. This regulatory volume already permits one to affirm, with reasonable certainty, that Artificial Intelligence Law constitutes an autonomous legal branch in formation — just as judicial precedents, formerly treated as a mere procedural appendix, have already consolidated their dogmatic independence. In Brazil, the regulation of this new branch — which encompasses not only civil procedure, but criminal procedure, administrative sanctioning law and public security — should be incorporated into curricula by the Ministry of Education, being recognised as a mandatory legal discipline in law schools. The formation of a new generation of jurists capable of operating with data, statistics and algorithms is a necessary condition for Law not to be overtaken by technology. 7. Conclusion Artificial intelligence is not a problem for Law: it is a historic opportunity to overcome its deepest dysfunctions — decisional opacity, normative fragmentation, investigative selectivity and structural sluggishness. But this opportunity is only realised if legal institutions have the courage to rebuild themselves. The Brazilian Public Prosecution Service has, in this context, a singular position: it is the holder of the investigatory power, the guardian of fundamental rights and the institution with the greatest capacity to assume leadership in the reorganisation of national public security on technological foundations. To do so, it will need to abandon the logic of speculative charges and embrace the culture of exhaustive investigation, qualified statistics and auditable artificial intelligence. The path is long, but the trail already exists. Brazil can follow it — provided its institutions have the willingness to begin. References BRAZIL. Constitution of the Federative Republic of Brazil of 1988. Brasília: Federal Senate. BRAZIL. Law No. 12,850, of 2nd August 2013. Provides for criminal organisations. Official Gazette. BRAZIL. Law No. 13,709, of 14th August 2018. General Data Protection Law (LGPD). Official Gazette. BRAZIL. Supreme Federal Tribunal. ADPF 1143. Reporter: Justice Alexandre de Moraes. STF, 2024. EUROPEAN PARLIAMENT. Regulation (EU) 2024/1689 — Artificial Intelligence Act. Official Journal of the European Union, 2024. GARCIA, Emerson. Ministério Público: organização, atribuições e regime jurídico. 7th ed. São Paulo: Saraiva, 2020. NOVOA MONREAL, Eduardo. El derecho como obstáculo al cambio social. 15th ed. México: Siglo XXI, 2010. OSÓRIO, Fábio Medina. Legal databases, artificial intelligence and the fundamental right to comprehension. Revista dos Tribunais, v. 1070, 2025. PALANTIR TECHNOLOGIES. Palantir Gotham: Platform Overview. New York: Palantir, 2023. PREDPOL. Crime Prediction Software — Technical White Paper. Santa Cruz: PredPol Inc., 2022. Fábio Medina Osório · International Institute for the Study of State Law.