Compliance and Investigations: the highlights that marked June 2026

Corruption investigations in Brazil gain new cooperation channel with Asia

Cooperation between anti-corruption authorities in Brazil and Hong Kong reinforces the trend toward the internationalization of investigations and asset recovery. For companies with operations or financial flows abroad, especially in Asia, the development indicates greater integration among authorities and reinforces the importance of compliance programs capable of preventing, detecting, and responding to transnational risks.

Companies within the same group may share anti-corruption risks, STJ considers

The case before the Superior Court of Justice (STJ) may define the scope of joint and several liability for companies belonging to the same corporate group under the Anti-Corruption Law. The discussion reinforces the importance of integrated compliance programs, with controls, training, due diligence, and reporting channels effectively implemented across all relevant entities of the group, especially in the context of corporate reorganizations, M&A, and investments.

Mental health enters the governance agenda and strengthens corporate compliance

The update to NR-1 expands occupational health and safety management by requiring the identification and treatment of psychosocial risks, such as harassment, overload, and excessive pressure. From a compliance perspective, the change reinforces the need to integrate these risks into corporate governance, internal controls, and reporting channels, promoting preventive and coordinated action among compliance, HR, audit, and risk management.

Financial crime and international sanctions raise the compliance bar for financial institutions and companies

Recent investigations into the use of financial structures to move illicit funds, combined with the tightening of international sanctions rules applicable to institutions involved in processing certain transactions, reinforce a trend of increasing regulatory expectations regarding financial governance and anti-money laundering controls.

STF reinforces intent requirement for administrative improbity

The Federal Supreme Court?s decision reinforces that liability for administrative improbity requires proof of intent, ruling out sanctions based solely on negligence or procedural failures and highlighting the importance of documentation, governance, and traceability of decision-making processes in organizations that interact with the public sector.

Norway increases predictability in transnational corruption cases

The new policy issued by the Norwegian authority Økokrim seeks to increase predictability in the application of sanctions for transnational corruption, providing reductions for companies that self-report, cooperate with investigations, and improve their internal controls. The development reinforces the international trend of combining deterrent effect with incentives for cooperation, requiring globally active companies to maintain compliance programs capable of effectively preventing, detecting, and remediating corruption risks.

CGU Observatory

The June PARs reveal an active month involving sectoral ministries in the investigation of fraud and irregularities in federal bids and contracts, conduct such as self-dealing or third-party favoritism, irregular granting of benefits, licenses, or authorizations, non-compliance with rules and regulations, disreputable conduct, financing or funding of unlawful acts under Law No. 12,846/2013 (Anti-Corruption Law), as well as the use of intermediaries to obtain undue advantages before the public administration.

National Highlights

Corruption investigations in Brazil gain new cooperation channel with Asia

The formalization of cooperation between anti-corruption authorities in Brazil and Hong Kong reinforces a trend toward the increasing internationalization of investigations and asset recovery. More than an exchange of best practices, the initiative provides for cooperation in investigations, corruption prevention, and the promotion of integrity, strengthening authorities’ capacity to act in cases involving cross-border elements.

The measure should be analyzed within a broader movement of Brazil’s closer engagement with global integrity and enforcement networks. In recent years, the Office of the Comptroller General has expanded its participation in international anti-corruption forums, promoted joint training initiatives, and strengthened relationships with foreign authorities. In this context, the formalization of cooperation with Hong Kong represents another step in building channels that may, in the future, facilitate the exchange of information, the conduct of coordinated investigations, and the recovery of assets located abroad.

The topic is particularly relevant for organizations that maintain corporate structures, holding companies, investments, or financial flows in Asia. Hong Kong occupies a strategic position as an international financial center and is often part of global corporate chains used for investments and business expansion. As cooperation between authorities advances, companies should be prepared for an environment in which information related to international operations may be subject to greater regulatory and investigative scrutiny.

For organizations, the main message lies not in the agreement itself, but in the trend, it represents anti-corruption and anti-fraud enforcement is becoming increasingly globally connected. Companies with international exposure should assess whether their compliance programs are prepared for a more integrated enforcement environment, in which cooperation between authorities from different countries is likely to become more frequent, agile, and comprehensive. In this context, periodic risk reviews, the enhancement of internal controls, and the strengthening of corporate governance play a central role in protecting the business and demonstrating a commitment to international integrity standards.

Companies within the same group may share anti-corruption risks, STJ considers

The Superior Court of Justice (STJ) is reviewing a case that may define the scope of joint and several liability under the Brazilian Anti-Corruption Law for companies belonging to the same corporate group. The case discusses whether parent companies, subsidiaries, affiliates, and other related entities may be held jointly liable for acts of corruption, even in scenarios involving corporate reorganizations or where there was no direct participation in the facts under investigation.

For companies, the most relevant point is not the specific case, but the possibility of consolidating a broader interpretation of corporate liability. If this understanding prevails, corruption risks identified in one entity may have significant repercussions for other companies within the group, increasing exposure to investigations, financial sanctions, and reputational damage.

The case reinforces the need for an integrated compliance approach within corporate groups. It is not enough for only one company to have adequate controls: policies, training, due diligence processes, monitoring mechanisms, and reporting channels must be disseminated and effectively implemented across all relevant entities of the group.

The discussion also serves as a warning for mergers, acquisitions, corporate restructurings, and investments, in which integrity risk assessments should include not only the target company, but also its entire compliance history and potential regulatory contingencies. In a scenario of possible expansion of liability, the preventive management of these risks becomes increasingly strategic to protect the corporate group as a whole.

Mental health enters the governance agenda and strengthens corporate compliance

With the recent update of Regulatory Standard No.1 (that establishes the general occupational health and safety guidelines in Brazil), companies are now required to identify, assess, and manage so-called psychosocial risks, including factors such as harassment, work overload, excessive working hours, pressure to meet targets, and other situations that may affect workers’ mental health. In addition to expanding oversight on the matter, the change reinforces the need to adopt preventive measures and continuously monitor these risks.

From a compliance perspective, the NR-1 update represents more than an obligation related to occupational health and safety. The standard reinforces the need for companies to incorporate psychosocial risks into their governance structure, internal controls, and corporate risk management.

Issues such as harassment, abuse of power, failures in organizational culture, and deficiencies in reporting mechanisms are no longer merely labor-related matters and now require strategic attention from integrity programs.

In this context, integration among compliance, human resources, internal audit, and risk management becomes essential to ensure the proper identification and handling of conduct that may generate regulatory, reputational, or operational impacts.

For organizations, the key message is that regulators and enforcement authorities now expect a more structured approach to preventing risks related to the work environment. The effectiveness of compliance programs is likely to be assessed not only based on the existence of formal policies and controls, but also on the company’s ability to promote a culture of integrity, respect, and prevention of inappropriate conduct.

Financial crime and international sanctions raise the compliance bar for financial institutions and companies

Two recent initiatives, one in Brazil and one in the United States, highlight the increasing regulatory and investigative pressure on financial institutions, financial technology companies, and other organizations that may, directly or indirectly, be used to facilitate the movement of illicit funds. In Brazil, authorities launched an operation to investigate the use of payment platforms and financial structures in a billion-dollar money laundering scheme linked to organized crime, with indications of financial transactions inconsistent with the declared economic activity and significant failures in monitoring and identifying suspicious transactions.

The investigations reinforce the growing expectation that companies adopt robust anti-money laundering mechanisms, effectively know their customers, partners, and financial flows, and maintain controls capable of identifying risks before they materialize.

In parallel, U.S. authorities have indicated that financial institutions and intermediaries involved in wire transfers related to criminal organizations designated as Foreign Terrorist Organizations (FTOs) may be subject to sanctions, significantly expanding the potential extraterritorial effects on companies that operate internationally or maintain cross-border business relationships.

This scenario reflects the growing convergence between domestic investigations and international initiatives to combat financial crime. Companies with cross-border operations, access to the international financial system, or relationships with foreign institutions should assess whether their compliance programs adequately address risks related to money laundering, financing of illicit activities, and international sanctions.

For companies across various sectors, and not only those in the financial market, but the current environment also calls for a preventive approach. The review of financial compliance programs, the updating of risk matrices, the implementation of risk-based due diligence processes, the strengthening of KYC/KYP procedures (Know Your Customer/Know Your Partner), the assessment of exposure to international sanctions, and the conduct of internal investigations and transaction tests have become strategic measures to reduce regulatory, reputational, and operational risks in an environment of increasing enforcement and international cooperation among authorities.

STF reinforces intent requirement for administrative improbity

The Federal Supreme Court (STF) unanimously upheld a provision of the Administrative Improbity Law, as amended by Law No. 14,230/2021, which makes liability for improbity conditional upon proof of intent, that is, evidence of the intention to commit the unlawful act. As a result, the Court reaffirmed that there is no administrative improbity in the negligent modality, ruling out the possibility of sanctions based solely on negligence, recklessness, or malpractice.

The decision is part of a broader judgment concerning provisions of the new Administrative Improbity Law, which has not yet been concluded. Among the points already reviewed, the Supreme Court also upheld the provision stating that differences in legal interpretation, when based on case law, do not constitute improbity, and recognized the constitutionality of the legal definition of a specific list of sanctionable conducts.

From the perspective of both public and private compliance, the ruling reinforces the need to distinguish administrative irregularities, procedural failures, and intentional unlawful acts. Although the decision raises the evidentiary burden for characterizing improbity, it does not reduce the relevance of internal controls, decision-making records, legal and technical opinions, and evidence of good faith, especially in relations with the Public Administration.

For companies that contract with the government or interact with public officials, the scenario calls for heightened attention to process documentation, decision traceability, and the adoption of robust integrity policies. The consolidation of more objective criteria for liability tends to provide greater legal certainty, but it also requires maturity in governance and in the prevention of conduct that may be interpreted as aimed at obtaining an undue advantage.

Thus, the Supreme Court?s decision represents a relevant milestone in the interpretation of the Administrative Improbity Law, by aligning sanctioning liability with proof of intent. At the same time, it reinforces that effective compliance programs remain essential tools to mitigate risks, demonstrate diligence, and preserve trust in relations between the private sector and the Public Administration.

International Highlights

Norway increases predictability in transnational corruption cases

The Norwegian authority responsible for investigating and prosecuting economic and environmental crimes, Økokrim, has published new guidelines on the application of sanctions to companies in cases involving corruption committed abroad. The measure seeks to provide greater predictability to state enforcement, particularly regarding the criteria for calculating penalties and the factors that may justify reductions, such as the existence of robust anti-corruption controls, self-reporting, cooperation with investigations, and the adoption of remedial measures.

Under the new policy, companies that voluntarily report misconduct before it is discovered by the authorities, and shortly after the facts are identified internally, may obtain a reduction of up to 50% of the penalty. An additional discount of up to 10% may also be granted to organizations that implement or improve controls aimed at addressing compliance failures. The guidelines further indicate that fines may be calculated based on the expected gain from the misconduct, the value of the undue advantage, or the company’s global turnover.

The initiative responds to a gap identified in the Norwegian system, which has been marked by a limited number of transnational corruption cases and the absence of consolidated case law on the calculation of corporate fines.

By clarifying what the authority considers to be incentives and consequences in sanctioning matters, the policy brings Norway closer to practices already observed in other relevant jurisdictions, such as the United Kingdom, France, the Netherlands, the United States and Brazil.

For companies with international operations, the guidelines reinforce the importance of effective integrity programs capable of detecting irregularities, documenting decisions, preserving evidence, and enabling timely responses. Regulatory predictability tends to encourage cooperation with authorities, but it also increases the expectation that companies will concretely demonstrate the maturity of their prevention, detection, and remediation mechanisms.

The Norwegian development confirms a broader trend in anti-corruption enforcement: authorities are seeking to combine deterrent effect with objective incentives for cooperation and the improvement of internal controls. In this context, companies exposed to transnational corruption risks should continuously assess their compliance programs, particularly regarding third-party governance, reporting channels, internal investigations, and criteria for potential self-reporting.

CGU Observatory

In June 2026, the administrative proceedings initiated by the CGU involved several public bodies under the authority?s oversight for purposes of commencing the PAR.

Authorities Involved:

• Ministry of Mines and Energy
• Office of the Comptroller General
• Ministry of Transport
• Ministry of Finance

Subject Matter of the Allegations:

• Self-dealing or third-party favoritism, irregular granting of benefits, licenses, or authorizations;
• Irregularities defined in rules or regulations;
• Disreputable conduct;
• Financing, funding, sponsorship, or subsidizing unlawful acts under the Anti-Corruption Law (Law No. 12,846/2013);
• Irregularities or fraud in bidding processes or contracts.
• Concealed use of an intermediary to obtain an undue advantage before the national public administration.

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