Competition Compliance In Brazil: Retrospective And Perspective

I. INTRODUCTION

Most compliance-related efforts by Brazilian authorities in the spotlight today are related to anticorruption enforcement, as a result of the legal framework in place since 2014, which introduced investigative tools that enforce corruption and promote the adoption of corporate compliance programs, and of the overall attention received by the Car Wash Investigation, in Brazil and abroad. Interestingly though, anticorruption compliance was the not the first area - and most certainty is not the only one - where compliance initiatives have prospered in Brazil.

Over twenty years ago, the National Monetary Council issued Resolution No. 2,554/1998 promoting the adoption of compliance programs to prevent money laundering, terrorism financing and systemic and prudential risks. And only a few years later in 2004, the competition authority in charge of investigations at the time (Secretariat of Economic Law or "SDE") issued Ordinance No. 14/2004 that for the