Eduardo Amorim, a partner with FBT Gibbons, sat down with host Scott Moritz for the Fraud Eats Strategy podcast to discuss key steps companies must focus on when considering an investment or expanding their operations in Brazil.
“Companies must understand the legal and political framework,” Amorim says. “Brazil’s anti-corruption law imposes strict liability on corporations. That means there’s no intent requirement for the law to be applicable. So, if a corrupt act benefits the company even indirectly, liability can attach, and penalties can reach up to 20% of gross revenue.”
He also stressed companies must conduct ongoing due diligence as they are directly responsible for third-party misconduct under Brazilian law.
“Companies should operate as if today’s law enforcement environment in Brazil could become tomorrow’s crackdown,” Amorim adds. “Enforcement cycles fluctuate in Brazil, but liability does not.”
Listen to the podcast episode, “Braving Brazil – Operating in Latin America’s Largest Economy in Uncertain Times.”