Compliance and Investigations: the highlights that marked February 2026

The month of February 2026 began marked by significant movements in the Compliance and Investigations landscape, highlighting an increasingly dynamic regulatory environment driven by new expectations of governance, transparency, and risk management.

National Highlights

Public Prosecutor’s Operation Exposes Compliance Failures in the Electronic Distribution Chain

The São Paulo Public Prosecutor’s Office, together with the Civil Police and the State Department of Finance, launched an operation to dismantle a criminal organization made up of Chinese businesspeople linked to the PCC, suspected of moving approximately R$ 1.1 billion in seven months through a money-laundering scheme involving the sale of electronic products. Sales were conducted through a main platform, while payments were diverted to shell companies acting as “pass-through accounts,” with invoices issued by third parties to create an appearance of legality.

Investigations indicate that PCC members were used as nominee partners and as beneficiaries of luxury real estate and vehicles, with the aim of shielding illicit assets. The operation executed 20 search-and-seizure warrants and three arrest warrants in São Paulo and Santa Catarina, resulting in the seizure of vehicles and the freezing of up to R$ 1.1 billion in assets, including approximately R$ 25 million in high-end properties and multiple bank accounts held in the names of “straw men.”

Authorities are also investigating whether there was a relationship of mutual support between the businesspeople and the criminal faction—both for logistical protection and for the potential use of the same structures to launder proceeds from organized crime. The case began following a complaint from a consumer who was instructed to pay for a purchase outside the official platform, revealing signs of the fraudulent scheme.

The episode underscores the relevance of integrity controls capable of identifying shell companies, suspicious payment structures, and inconsistencies in registration data. It reinforces the need for robust compliance programs, including third-party due diligence, continuous monitoring, and verification of ultimate beneficial owners, in order to prevent legal, financial, and reputational risks arising from organized crime infiltrating supply chains.

Brazil Remains in Its Worst Corruption Ranking and Puts Pressure on the Advancement of Compliance Practices

Brazil maintained in 2025 its worst historical position in the Corruption Perceptions Index (CPI) prepared by Transparency International, remaining in 107th place among 182 countries, with 35 points on a scale from 0 to 100. The performance is considered stagnant, as a one-point variation from the previous year is statistically irrelevant. The country remains below both the global and the Americas averages, each at 42 points, reinforcing its distance from international standards of public integrity.

The NGO’s report also points to a worsening of organized crime’s infiltration into the Brazilian state, highlighting cases of grand corruption such as the scandals involving the INSS and Banco Master, which expose structural weaknesses in the financial and legal sectors, areas considered strategic for illicit practices. In addition, Transparency International draws attention to the sharp increase in parliamentary budget amendments, which exceeded R$ 60 billion in the 2026 budget, indicating a movement toward “budget capture” by the Legislative Branch.

The document also mentions suspicions related to high-value contracts between Banco Master and law firms linked to STF authorities, underscoring the need for independent investigations. The results keep Brazil far from the performance of higher-ranked countries such as Denmark, Finland, and Singapore, and reinforce an international perception of stagnation and fragility in anti-corruption prevention mechanisms, which highlights the importance of strengthening compliance practices, especially in the public sector and in public–private relationships nationwide.

Workplace Harassment on the Rise: A Challenge for Integrity

Complaints and lawsuits related to workplace bullying (moral harassment) increased significantly in 2025. The Superior Labor Court (TST) recorded more than 142,000 new cases, representing a growth of over 20% compared to the previous year, while the Labor Prosecutor’s Office (MPT) received more than 18,000 complaints. The Disque 100 hotline also recorded a sharp increase, with nearly 50% more reports than in 2024.

The growth is attributed both to increased awareness and to strengthened reporting channels. The TST published a Prevention Guide on Harassment, providing guidance on identifying abusive conduct and how to act when witnessing it, reinforcing that repeated humiliation, abusive targets, isolation, and public shaming constitute workplace bullying (moral harassment).

Legislation provides for severe accountability for employers and managers, including constructive dismissal due to serious misconduct and the opening of administrative proceedings in the public sector. There is also a bill under discussion to classify workplace bullying as a criminal offense, providing for detention and a fine.

The issue has become even more relevant in light of the rise in leave of absence due to mental disorders, which reached the highest level of the decade. In response, an update to NR-1 was announced to include psychosocial risks in workplace mental-health guidelines, enabling inspections and the application of fines, although its full implementation was postponed after business-sector pressure.

Compliance in Public Bidding Processes: CGU Formalizes an Agreement and Reinforces Obligations

The Office of the Comptroller General of Brazil (CGU), pursuant to Law No. 12,846/2013, entered into a Commitment Term with Telemática Sistemas Inteligentes Ltda., Seguridade Integrada Comércio e Serviços Ltda., and Aceleratec Comércio e Integração Ltda., as per the excerpt published in the Official Gazette (DOU) on February 4, 2026.

The established facts relate to irregularities in Petrobras procurement procedures, involving the submission of commercial proposals without independence, to the detriment of the competitive nature of the bidding processes.

Under the term, the companies admitted strict liability and assumed obligations such as ceasing involvement in the harmful act, responding to requests for information, waiving the submission of a defense, and paying a fine of BRL 169,095.01, to be paid within 30 days from the publication of the term.

The CGU further reported that it evaluated the integrity programs of the signatory companies (code of ethics and integrity, compliance policies, procedures, and internal controls), noting that updates and improvements had been made and that there is a commitment to the ongoing maintenance of the program. The case reinforces the relevance of compliance to prevent risks in contracting, ensure fair competition, and sustain a culture of integrity and accountability.

Reputational Risk and Administrative Sanctions: CGU Decisions Highlight the Importance of Internal Controls

Recent episodes involving financial institutions, private companies, and public programs convergently highlight the centrality of compliance, governance, and risk management for organizational sustainability and the preservation of market and societal confidence.

S&P’s downgrade of BRB’s rating, prompted by investigations related to the acquisition of Banco Master’s assets, illustrates how weaknesses in internal controls and reputational risks can pressure capital, affect access to funding, and compromise strategic focus and profitability in the short and medium term.

At the same time, the leniency agreements signed by the CGU and the AGU with companies in the agro-industrial sector, as well as the administrative convictions resulting from undue payments and fraud in public contracts, demonstrate the consistent performance of the State in holding unlawful acts accountable and inducing structural improvements in integrity programs.

Operation Over The Counter, aimed at combating fraud in the Popular Pharmacy Program, reinforces the need for robust controls of registration integrity, data governance, auditing and monitoring of transactions to protect public policies and prevent large-scale deviations.

Taken together, these cases show that compliance failures can result in relevant financial sanctions, operational constraints, and severe reputational damage, while effective investments in governance, risk prevention, detection, and response are key to reducing legal exposures, ensuring business continuity, and promoting a culture of sustainable integrity.

International Highlights

Sweden Opens New AML Investigation into Swedbank

Sweden’s Financial Supervisory Authority (FSA) announced the opening of a new investigation to assess whether Swedbank has adequately complied with national anti-money laundering (AML) requirements, especially regarding know-your-customer (KYC) controls and due diligence measures. The review will cover the period from December 2023 to November 2025, focusing on the robustness of the bank’s internal processes to identify and mitigate financial crime risks.

The FSA stated that combating money laundering and terrorist financing will remain a regulatory priority in 2026 but did not clarify whether the new investigation results from a routine procedure or from specific indications of deficiencies. The news reinforces continued regulatory pressure on Swedbank, which has faced several controversies related to insufficient controls in prior years.

The announcement had an immediate market impact: Swedbank shares fell by about 1.3%, diverging from the European banking index, which rose over the same period. The decline reflects investor sensitivity to regulatory issues, particularly given the bank’s recent history, which included the conclusion—without penalties—of a U.S. Department of Justice investigation into possible shortcomings linked to the Baltic money-laundering scandal. The FSA’s decision occurs in a context of increasing rigor in the supervision of financial risks in Europe, reinforcing the importance of robust compliance frameworks, effective internal controls, and continuous monitoring.

U.S. Strengthens Incentives for Self-Disclosure of Market Crimes

The U.S. Attorney’s Office for the Southern District of New York (SDNY) announced a new Corporate Enforcement and Voluntary Self-Disclosure Program focused on financial crimes, aimed at encouraging companies to promptly report unlawful conduct involving fraud and other irregularities that affect market integrity. The program sets clear guidelines for companies that voluntarily disclose violations, fully cooperate with authorities, and implement remediation measures.

The key innovation is the granting of a conditional declination within as little as two to three weeks after self-disclosure, allowing the company to know in advance that it will not face criminal charges if it meets all requirements, including ongoing cooperation for three years and full restitution to victims. Once the obligations are fulfilled, the declination becomes final, closing the matter without the filing of formal charges.

The program also introduces clear consequences for companies that choose not to self-disclose: if the SDNY identifies criminal conduct, it is presumed that the resolution will involve a guilty plea, a deferred prosecution agreement (DPA), or a non-prosecution agreement (NPA), all accompanied by fines or restrictive measures. The policy reinforces the SDNY’s focus on individual accountability, investigative speed, and investor protection.

CGU Observatory

Trends in the PARs established in the month

In February 2026, the administrative proceedings initiated by the CGU involved several public bodies under the authority’s jurisdiction for the purposes of opening PARs.

Agencies Involved:

• Office of the Comptroller General (CGU)
• Ministry of Social Security
• Ministry of Mines and Energy
• Ministry of Culture
• Ministry of Communications

Facts Under Investigation:

• Irregularities or fraud in bidding processes or contracts
• Fraud in administrative procurement procedures
• Concealed use of an intermediary to obtain undue advantage before the public administration
• Breach of information confidentiality
• Financing/support/sponsorship/subsidies tied to acts of corruption as defined under the Brazilian Anti-Corruption Law (Law No. 12,846/2013)

This material is for informational purposes only. Our Compliance and Investigations team is available to provide specific legal advice.