Brazilian states are following the recommendations of the CGU
and implementing compliance programs.
Historically, there have not been any centralized laws
surrounding compliance in Brazil, which has led to problems with
corruption. That is now changing due to recommendations from The
Comptroller General of the Union (Portuguese: Controladoria-Geral
da União). Although the CGU, is not a governing body for
specific compliance matters, it has put into place recommendations
for states in Brazil to implement compliance programs.
Companies in Brazil that want to do business with state
governments are taking the suggestion of the CGU to set up
compliance programs. While this is not mandatory, there have been a
trend of states creating compliance programs in which they set
rules for a whistleblowing program, an ethics code and clearly
defined policies.
