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Integrity is do what is right. There’s no autonomy for the public agent to do what is wrong. Therefore, the compliance system would be useful to increase the political parties’ capacity to search for a true compliance culture.

Antonio Fonseca under general Public Attorney

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Public Attorney defends that political parties create their own compliance programs – During his attendance to the 1st Seminar of Electoral Compliance, under general Public Attorney Antonio Fonseca has defended that political parties create “effective compliance programs, based on their constitutional scope: vehicles to political power and answer to social needs”. So far, there’s no legal obligation for political parties to implement compliance programs, although they have been under a lot of pressure to build some control mechanisms, especially regarding public funds destined to finance electoral campaigns” (Terra, 2019.08.07)

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Department of Justice updates criteria for evaluation compliance programs – The United States Department of Justice updated its criteria to asses corporate compliance programs. The DOJ focused its update in three main issues: i) if the compliance program was well design; ii) if the program is effective; and iii) the effects that the program generates. The new criteria shall be observed by the federal prosecutors when negotiating plea agreements with companies charged for corruption. Recently, the evaluation of compliance programs became one of the most important standards when prosecutors decide to promote agreement with companies. (National Law Review, 2019.08.02)

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European Union call for its members to adopt more restrict mechanisms to fight money laundering – The European Commission – executive arm of EU -published four reports and an official communiqué calling its members to establish in their financial systems more effective policies to fight money laundering. Such call comes after several scandals involving banks from Latvia and Denmark, accused for carry billions of dollars from terrorists’ groups, mafia and even entities connected to North Korea. (Lexology, 2019.08;19)

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Brazilian Federal Controller publishes rule with internal procedures against companys charged with corruption – Brazilian Federal Controller, published in August 12th instruction n 13, which provides the internal procedure inside federal departments to investigate illegal acts by legal entities that generated damages for by public entities, as provided in Federal Law n 12846/2013 (Anticorruption law). The new rule revoked Internal Order n. 910/15 and it’s already in force (Migalhas. 2019.08.12)

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Petrobras review its Board of Directors limits – Besides being involved in several claims of political interference by the Bolsonaro administration, Petrobras have been increasing the approval limits for its Executive Officers, that now can approve, without the Board of Directors acceptance, investment projects up to US$ 1 billion – the previous limit was Us$ 500 million. The new rules have been criticized as they might show a slackening in governance matters, which is denied by the company (Valor Econômico, 2019.08.14)

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After Lava Jato, contractors create self-regulating entity – The biggest Brazilian contractors are setting up a self-regulatory institute, including a code of ethics for the industry, as they try to regain their image after years of negative exposure due to the consequences of the Lava Jato operation. (UOL Economia, 08.14.2019)

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FAPDF launches Integrity and Compliance Program in partnership with the Public Prosecutor and CGDF – On August 16, the Federal District Research Support Foundation (FAPDF) Integrity and Compliance Program was launched. The main objective of the program is to create a healthy and effective environment for the proper execution of the foundation’s resources. (Valor Econômico, 08.14.2019)

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Witzel signs decree creating Rio’s integrity program for servers – Governor Wilson Witzel signed a state decree creating the integrity program to apply to state officials. The program comprises a series of initiatives aimed at combating, preventing and remedying corruption. (O Globo, 08.22.2019)

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São Paulo Municipality begins compliance program with 27 secretariats and other bodies – The Comptroller General of the City of São Paulo received 27 voluntary adhesions from the Secretariats and Subprefectures to the Integrity and Good Practices Program, the compliance of the largest Brazilian city. This number represents 48% of participation among all 56 organs of the Direct Administration of São Paulo City Hall. The work will be developed during the second semester and is part of the 2019/2020 Goals Program which provides for the increase to 6.25 of the Municipality Integrity Index. (Veja, 08.29.2019)

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Odebrecht studies compliance program budget cut – Odebrecht’s budget for the compliance program, set up after the leniency agreement with Brazilian agencies and the US Department of Justice (DOJ) is being cut, is in the wake of the group’s spending cuts on account of of judicial recovery. The issue is on the board table and is very sensitive to the company, which urgently needs to rebuild its image to regain market and generate revenue. (Valor Econômico, 08.29.2019)

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Get To Know More
Do you want to know how does money laundry work and why fight it is one ot the top priorities of compliance programs, especially the ones from financial entities? These graphics created by McKinsey shows in a very user friendly layout the impact that money laundry has in the global financial system and the advantages of implement efficient Anti Money Laundering (AML) mechanisms.

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Compliance Desk