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ARTICLE · 08 SEPTEMBER 2015

Proposal Of Guidelines For Competition Compliance Programs

Mayer Brown
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On August 19, 2015, the Administrative Council for Economic Defense ("CADE") submitted to the public for comments the preliminary version of the Guidelines for Competition Compliance Programs ("Guide").

BrazilAntitrust/Competition Law
Eduardo Gaban
Eduardo Gaban
Paulo Casagrande
Paulo Casagrande
Fernanda Calmon
Fernanda Calmon
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On August 19, 2015, the Administrative Council for Economic Defense ("CADE") submitted to the public for comments the preliminary version of the Guidelines for Competition Compliance Programs ("Guide") 1.

The most important aspect of the Guide is that Cade signals that the adoption of effective compliance programs may result in a reduction in the fines imposed on companies that engage in anticompetitive conduct.

The Guide provides that when applying the penalties contemplated by the Brazilian Competition Law (Federal Law no. 12529/2011), CADE's Tribunal may consider variables such as the good faith of the party in breach, which may be demonstrated by the adoption of an effective compliance program.

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