Compliance Due Diligence In M&A Transactions

The fight against corruption in Brazil gained momentum in recent years, with many investigations launched by the Prosecutors' Office ("Ministério Público") and the Federal Police ("Polícia Federal"), among which Operation Car Wash ("Operação Lava Jato") is the most prominent example. Furthermore, the enactment of the Anti-Corruption Law (Law No. 12,846, of August 1st, 2013), which is in line with foreign legislation, such as the US Foreign Corrupt Practices Act (FCPA) and the UK Bribery Act, as well as Brazil's Supreme Court's ruling to enforce jail sentences after a second instance order is issued – rather than waiting for a final non appealable decision – also helped to dramatically change the corporate and business environment in Brazil.