In this inaugural episode of the FCPA Compliance Report-International Edition, I have Carlos Ayres, a partner in Madea, Ayres and Sarubbi in Sao Paulo. We discuss an  interesting development from the Odebrecht corruption scandal, federal prosecutors in Brazil and ten other countries recently announced they had agreed to cooperate in ongoing investigations surrounding the company. The Odebrecht case involved bribery and corruption allegations reaching multiple countries throughout the Americas. Now reports indicate that officials from Brazil, Argentina, Chile, Colombia, the Dominican Republic, Panama, Mexico, Peru and even the notoriously corrupt Venezuela, along with the European nation of Portugal, have agreed to “start a combined task force with bilateral and multilateral investigative teams to coordinate a probe” of the company. We also discuss recent reports which indicate show companies in Brazil are taking this approach in response to the country’s more aggressive enforcement against endemic corruption in commercial businesses. This is partly in response to the allegations and investigations brought forward by Operation Car Wash and the attendant Odebrecht anti-corruption enforcement action. Jorge Abrahão, president of Brazil’s Ethos Institute, a corporate social responsibility organization said “We are witnessing a big change in Brazil—there is an understanding in society now that whoever doesn’t take the issues of corruption and transparency seriously will not have a place in the market in the future.

For More Information on these topics see my blog posts:

  1. A South American Response to Corruption
  2. Companies now doing compliance in Brazil

Carlos Ayres can be reached via email at