Brazilian anti-corruption authority updates its Corporate Compliance Program Guidelines

New guidance includes implementing proactive risk management and defining management and control practices with an emphasis on ESG.

It has been 10 years since the Brazilian Law N.º 12,846/2013 (Brazilian Anti-Corruption Law or BACL) came into force, establishing the strict liability of companies for corrupt acts against national and foreign government officials.

At the time, there were many doubts about whether the BACL would be highly enforced in Brazil. The

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