Brazil’s New Anti-Corruption Law: What Every Multinational Employer Should Know

On August 1, 2013, Brazil enacted Law 12.846, a new anti-corruption law that establishes a comprehensive system of corporate and individual liability for acts of corruption against Brazilian and foreign public officials or governmental bodies.1 The new anti-bribery law becomes effective on January 28, 2014. Companies conducting direct or indirect activities in Brazil – whether through an employee, independent contractor, subsidiary, or as part of a supply chain – should pay special attention to the contours of this law, the severe penalties for violations, and recommended steps to ensure full compliance.