Compliance and Investigations: the highlights that marked August 2026

Money laundering and complex structures: The role of compliance in protecting businesses

Recent cases highlight the increasing sophistication of schemes that use legitimate companies and ordinary business operations to move illicit funds, underscoring the need for robust compliance, anti-money laundering (AML), and third-party risk management programs.

New U.S. enforcement priorities raise expectations for compliance programs

The latest enforcement priorities announced by U.S. authorities signal heightened scrutiny of corruption, fraud, sanctions, public procurement, and international trade risks, reinforcing the need for periodic compliance assessments, continuous monitoring, and regular testing of the effectiveness of corporate controls.

Growing sanctions-related litigation reinforces the importance of proactive risk management

Increasing scrutiny of international sanctions underscores the importance of risk assessments, third-party due diligence, and periodic reviews of compliance controls, particularly for organizations with international operations or exposure to global supply chains.

Corporate transparency in transition: Impacts on compliance and third-party risk management

Recent regulatory changes in the United States reinforce that risk mitigation increasingly depends on companies’ ability to conduct integrity investigations, identify beneficial owners, and understand the ownership structures of their counterparties, particularly in international operations and highly regulated sectors.

Accounting fraud returns to the center of U.S. regulatory priorities

The renewed regulatory focus on accounting fraud in the United States signals heightened scrutiny of financial reporting, internal controls, audits, and the quality of information disclosed to the market. This trend reinforces expectations that companies implement effective mechanisms for preventing, detecting, and reporting misconduct, particularly in areas exposed to elevated fraud and governance risks.

CGU Observatory

The administrative proceedings (PARs) initiated in August 2026 reflect the authorities? increasing focus on conduct involving corruption, fraud in public procurement and government contracts, financing of illicit activities, the use of intermediary entities to obtain undue advantages, and interference with government oversight and investigative activities. This enforcement landscape highlights the growing importance of strengthening corporate governance, third-party risk management, and internal controls, particularly for organizations operating in regulated sectors or maintaining relationships with public authorities.

National Highlights

Money laundering and complex structures: The role of compliance in protecting businesses

Recent developments in investigations concerning the infiltration of organized crime into sectors of the formal economy reveal an increasingly sophisticated landscape of money laundering and asset concealment mechanisms in Brazil. Ongoing inquiries indicate the use of corporate structures, payment institutions, investment funds, and participants in the fuel supply chain as vehicles for the movement and concealment of proceeds derived from illicit activities. These findings highlight that integrity risks are no longer confined to sectors traditionally regarded as high-risk.

One of the key aspects underscored by the investigations is the ability of criminal organizations to use formally established companies and seemingly legitimate business transactions to introduce illicit funds into the economy. Authorities have identified alleged schemes involving fuel adulteration, the use of forged documents, complex financial structures, and mechanisms designed to obscure the identification of the ultimate beneficial owners of the funds being transferred.

Another significant element has been the impact of these investigations on commercial relations between large corporations and third parties potentially exposed to integrity risks. In a recent case, a major company in the oil and gas sector suspended it´s supply arrangements with a fuel distributor following compliance and risk management assessments conducted based on the publicly available information and investigations carried out by competent authorities.

The case demonstrates that significant business decisions are increasingly influenced by compliance assessments, anti-money laundering (AML) risks, and potential implications arising from international sanctions regimes.

The investigations also draw attention to the growing use of payment institutions, fintech companies, and investment vehicles as potential tools for concealing assets and circumventing traditional financial monitoring mechanisms. Authorities have reported the movement of billions of reais through sophisticated financial structures, as well as the use of investment funds and multiple layers of corporate ownership designed to hinder the identification of the ultimate beneficial owners behind transactions.

From a compliance perspective, these cases reinforce a globally observed trend: the expectation that companies know not only their customers and direct business partners, but also the ownership structure and ultimate beneficial owners involved in their commercial relationships. The mere absence of criminal convictions or formal sanctions is no longer sufficient to eliminate risks of reputational, regulatory, or operational exposure. Across a range of industries, particularly those characterized by significant financial flows, complex distribution chains, or substantial reliance on third parties, adopting risk-based approaches and continuous monitoring is becoming increasingly important.

International Highlights

New U.S. enforcement priorities raise expectations for compliance programs

U.S. authorities recently announced their key corporate fraud enforcement priorities, signaling heightened scrutiny of companies and an expanded use of technology and data analytics to detect misconduct. Priority areas include fraud involving government contracts, bribery and corruption in procurement processes, accounting and billing fraud, misconduct relating to government programs, tax fraud, international trade violations, sanctions evasion, and other forms of corporate wrongdoing.

The new enforcement guidance also places particular emphasis on international trade risks and global supply chains. Authorities have indicated their intention to intensify investigations involving false product origin declarations, import undervaluation schemes, efforts to circumvent trade restrictions, and potential violations of economic sanctions regimes. This development warrants special attention from companies engaged in international business or that rely on third parties for import, export, and logistics activities.

Another significant aspect is the growing reliance on data-driven enforcement efforts. The monitoring and analysis of billing data, payment flows, commercial transactions, and regulatory filings are expected to be used more extensively to identify unusual patterns and potential indicators of fraud, even in the absence of whistleblower reports or internal complaints.

This development further underscores the importance of preventive controls, continuous monitoring, and mechanisms capable of detecting misconduct before it is identified by regulatory or enforcement authorities.

The guidance also emphasizes that companies which identify misconduct internally, conduct appropriate investigations, implement remedial measures, and cooperate with authorities may receive more favorable treatment in potential enforcement proceedings. This message aligns with a broader global trend toward recognizing and rewarding organizations that demonstrate an ability to identify risks promptly and maintain effective compliance programs.

From a practical perspective, the update serves as a reminder for organizations to reassess their third-party due diligence processes, international trade compliance controls, anti-corruption programs, transaction monitoring frameworks, tax compliance controls, and internal investigation procedures. It also highlights the importance of periodically evaluating the effectiveness of compliance programs, particularly for companies with international operations, significant interactions with the public sector, or exposure to complex regulatory risks.

Growing sanctions-related litigation reinforces the importance of proactive risk management

In the United States, there has recently been a resurgence of lawsuits brought by individuals and entities seeking to challenge or reverse their designation under economic sanctions programs. Following a period of relative decline in such cases, practitioners have identified a renewed wave of challenges to restrictive measures, reflecting the growing importance of sanctions regimes as tools of economic policy and national security.

While the development is primarily focused on efforts by sanctioned parties to secure their removal from sanctions lists, the key takeaway for the private sector extends well beyond the litigation itself. The increase in these disputes highlights the significant consequences that sanctions designations can have for individuals and businesses, including restrictions on commercial activities, asset freezes, limited access to the financial system, and potentially severe reputational impacts.

This environment reinforces the importance of preventive controls aimed at identifying sanctions-related risks. Companies with cross-border operations, complex supply chains, or relationships with distributors, agents, business partners, and foreign customers should ensure that their due diligence and monitoring processes include periodic screening against sanctions lists, as well as mechanisms designed to identify indirect connections to sanctioned parties.

The trend also highlights the increasing sophistication of authorities in the implementation and enforcement of restrictive measures, particularly in matters involving international trade, exports, cross-border financial transactions, and complex corporate structures. In this context, deficiencies in third-party screening processes or failures to identify the ultimate beneficial owners of counterparties may result in significant regulatory exposure, even where a company has no direct dealings with a sanctioned party.

For organizations, the evolution of this landscape presents an opportunity to reassess sanctions compliance programs, continuous monitoring processes, and escalation protocols for potential sanctions-related alerts. Independent reviews of these mechanisms can help reduce regulatory risks, prevent operational disruptions, and demonstrate that the company has adopted measures proportionate to the growing expectations of regulators, enforcement authorities, and financial institutions.

Corporate transparency in transition: Impacts on compliance and third-party risk management

The U.S. government has announced the permanent elimination of beneficial ownership information (BOI) reporting requirements for U.S. companies and individuals, reversing one of the central corporate transparency measures established under the Corporate Transparency Act (CTA), legislation originally designed to strengthen efforts to combat money laundering, corruption, fraud, and the concealment of assets. Under the new rules, limited reporting obligations remain in place for certain foreign entities, while domestic companies are no longer required to submit beneficial ownership information. The changes also provide for the removal of information that had previously been reported to authorities.

The development has sparked debate among government agencies, compliance professionals, and policy experts, particularly regarding its potential impact on financial investigations and the reduced availability of information concerning the individuals who ultimately own or control corporate structures. Critics argue that the absence of such information may hinder efforts to identify shell companies and structures used for illicit purposes, including sanctions evasion, money laundering, and financial fraud.

For companies, financial institutions, and other organizations subject to compliance obligations, the announcement reinforces an important message: even where regulatory requirements are relaxed, market expectations regarding the identification of ultimate beneficial owners and a thorough understanding of third parties remain high.

In practice, the reduced availability of public or government-held ownership information may increase the need for independent due diligence procedures, document verification, and integrity investigations to better understand who ultimately controls customers, suppliers, business partners, and investors.

The issue is also highly relevant to anti-corruption, anti-money laundering (AML), sanctions compliance, and third-party risk management programs. Regulators, financial institutions, and business partners continue to expect companies to maintain a thorough understanding of their business relationships and to be able to identify potential conflicts of interest, exposure to politically exposed persons (PEPs), connections to sanctioned parties, or corporate structures used to conceal the ownership of assets and business activities.

In this context, the weakening of an official source of corporate ownership information is likely to increase the importance of private-sector compliance controls. Organizations with international operations or significant regulatory exposure should consider reviewing their know-your-customer (KYC), know-your-supplier (KYS), ultimate beneficial ownership (UBO) identification, third-party monitoring, and corporate investigations procedures in order to mitigate risks arising from the reduced availability of centralized ownership information.

Accounting fraud returns to the center of U.S. regulatory priorities

The U.S. Securities and Exchange Commission (SEC) has announced an enhanced focus on accounting fraud and financial reporting misconduct through the creation of a specialized unit dedicated to financial reporting and accounting matters. The initiative forms part of a broader “back-to-basics enforcement” strategy aimed at renewing attention on traditional securities law violations, including earnings manipulation, accounting misstatements, deficiencies in required disclosures, and misconduct by corporate officers, accountants, and auditors.

The new unit is also expected to expand the use of technology and artificial intelligence to analyze large volumes of information disclosed by public companies, identify trends and inconsistencies, and detect potential indicators of fraud. This development demonstrates that regulators are becoming increasingly capable of identifying irregularities through automated analytics, thereby increasing the likelihood that risks will be detected before whistleblower complaints or external investigations arise.

Beyond companies themselves, the initiative signals heightened scrutiny of professionals who serve as key gatekeepers, including accountants, auditors, and individuals responsible for financial controls. According to market observers, the SEC intends to strengthen its ability to hold accountable not only those directly involved in fraudulent conduct, but also those who fail to adequately identify, prevent, or report significant misconduct.

From a compliance perspective, the development reinforces the growing convergence of corporate compliance programs, corporate governance, and financial controls. Although the announcement originates from the U.S. capital markets environment, the underlying trend has global relevance, particularly for companies that access capital markets, maintain international operations, or are subject to heightened transparency expectations from investors, regulators, and financial institutions.

The evolving landscape underscores the importance of conducting periodic assessments of internal control effectiveness, accounting entry approval processes, financial reporting governance, reporting mechanisms, and whistleblower channels. Weaknesses in financial controls are frequently among the earliest indicators of fraud, corruption, conflicts of interest, asset misappropriation, and other forms of corporate misconduct, making close coordination among compliance, internal audit, legal, and finance functions essential.

CGU Observatory

In August 2026, the administrative proceedings initiated by the Office of the Comptroller General (CGU) involved several public entities under its oversight for the purpose of opening Administrative Accountability Proceedings (PARs).

Authorities Involved:

_Office of the Comptroller General (CGU)

_Ministry of Transport

_Ministry of Finance

_Ministry of the Environment and Climate Change

_Ministry of Agriculture and Livestock

Subject Matter of the Allegations:

_Use of intermediary entities to obtain undue advantages from the Public Administration;

_Improper conduct and irregularities or fraud in bidding procedures or public contracts;

_Offering or payment of undue advantages, directly or indirectly, to a domestic public official or a related third party;

_Financing, funding, sponsoring, or subsidizing unlawful acts under the Anti-Corruption Act (Law No. 12,846/2013);

_Obstructing or interfering with investigations or oversight activities conducted by public authorities or officials.

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