Who was sanctioned, and for what?

Arla Foods Ingredientes Comércio de Produtos Alimentícios Unipessoal Ltda. entered into a leniency agreement with the Controladoria-Geral da União (CGU, Office of the Comptroller General) and the Advocacia-Geral da União (AGU, Office of the Attorney General) concerning violations of the Anti-Corruption Law described in an unpublished annex; it had been the first to come forward, in October 2022. The alleged fine of BRL 31,056.36 derives from a preliminary fine of BRL 93,150.45, based on 2021 gross revenue of BRL 6,210,029.68, reduced by 66.66% for self-reporting, degree of cooperation and payment terms.

Authority / court

Controladoria-Geral da União (CGU) und Advocacia-Geral da União (AGU)

Area of law

Bribery and corruption

Legal basis

Lei nº 12.846/2013, Art. 16 und 17; Decreto nº 11.129/2022, Art. 22, 23 und 47; Lei nº 8.429/1992

Action

Fine

Status of proceedings

final

Sector

Food and agriculture

Mitigating circumstances

Total reduction of 66.66% (22.22% each for self-reporting, degree of cooperation and payment terms); compensation for losses, cooperation and voluntary admission also counted as mitigating factors in the calculation.

Liability of senior managers

As an aggravating factor, the CGU found that management tolerated or was aware of the acts (3% uplift).

Original amount 31,056.36 BRL, converted at the ECB reference rate of 23 Jul 2026.

Checked against the official source on 3 Oct 2026 · Direct link

From 2013 to 2019, Scoular had customs brokers pay around 400,000 USD to Mexican border and inspection officials so that trains carrying contaminated maize and grain would pass inspections; some of the money went to individuals close to cartels. Three-year DPA with a criminal penalty of 9,769,521 USD and forfeiture of 414,351 USD.

Authority / court

U.S. Department of Justice (Criminal Division, Fraud Section; USAO Western District of Texas)

Area of law

Bribery and corruption · Bribery of public officials

Legal basis

FCPA (Verschwörung zur Verletzung der Anti-Bestechungsvorschriften); Deferred Prosecution Agreement

Action

Fine

Status of proceedings

final

Sector

Food and agriculture

Culpability

intentional

Mitigating circumstances

Cooperation and remediation (including an overhaul of compliance, third-party management, financial controls and anti-corruption training); 25 % reduction off the low end of the sentencing guidelines range.

Liability of senior managers

Measures against individuals are not reported here.

Published

17 Jul 2026

Original amount 10,183,872 USD, converted at the ECB reference rate of 17 Jul 2026.

Checked against the official source on 28 Sep 2026 · Version 3 · Direct link

The CGU imposed on the Colônia dos Pescadores Z-12 do Médio Rio Doce a fine of BRL 7,180,921.47 and extraordinary publication of the decision. Acting together with others, the association had falsified its members' applications for entry in the fishing register (RGP) and backdated records and had interfered with the federal fisheries office in Espírito Santo, so that false data found their way into official documents and compensation from the Fundação Renova, together with lawyers' fees, was paid out without entitlement (Art. 5 II, III and V Lei 12.846/2013).

Authority / court

Controladoria-Geral da União (CGU)

Area of law

Bribery and corruption

Legal basis

Lei 12.846/2013, Art. 5 II, III und V, Art. 6 I und II, Art. 14; Decreto 11.129/2022, Arts. 19, 22 und 23

Action

Fine

Status of proceedings

unknown

Sector

Food and agriculture

Liability of senior managers

Measures against individuals are not set out here.

Published

5 May 2026

Original amount 7,180,921.47 BRL, converted at the ECB reference rate of 24 Apr 2026.

Checked against the official source on 3 Oct 2026 · Direct link

JBJ Agropecuária Ltda. and Prima Foods S.A. acknowledged, in a leniency agreement with the CGU and the AGU, that they had paid an economic advantage to a public official whose action or omission was in their interest (Art. 5 I Lei 12.846/2013). After a 66.6% reduction they allegedly pay fines totalling BRL 31,156,767.70 in three annual instalments and are jointly and severally liable for them. Payments under an agreement on the same facts with the Federal Public Prosecutor's Office (MPF) are credited.

Authority / court

Controladoria-Geral da União (CGU) und Advocacia-Geral da União (AGU)

Area of law

Bribery and corruption · Bribery of public officials

Legal basis

Lei 12.846/2013, Art. 5 I, Art. 6 I, Arts. 16 und 17; Decreto 11.129/2022

Action

Fine

Status of proceedings

final

Sector

Food and agriculture

Mitigating circumstances

For JBJ, credit was given for restitution or compensation (1%), cooperation (1.5%), voluntary admission (2%) and an applied compliance programme (2.5%); overall a 66.6% reduction on the full fine of BRL 93,283,735.64.

Liability of senior managers

For JBJ, tolerance or knowledge by management (3%) and the concurrence of several offences (3%) were aggravating factors.

Original amount 31,156,767.7 BRL, converted at the ECB reference rate of 26 Jan 2026.

Checked against the official source on 3 Oct 2026 · Direct link

Minerva S.A. acknowledged, in a leniency agreement with the CGU and the AGU, that it had paid economic advantages to public officials whose action or omission was in the company's interest. The full fine under Art. 6 I Lei 12.846/2013 of BRL 51,376,161.22 was reduced by 57.1% to BRL 22,040,373.16 (indexed to IPCA up to March 2025) and is allegedly payable to the Union. The amount and the facts have not been confirmed against the primary source.

Authority / court

Controladoria-Geral da União (CGU) und Advocacia-Geral da União (AGU)

Area of law

Bribery and corruption · Bribery of public officials

Legal basis

Lei 12.846/2013, Art. 6 I, Arts. 16 und 17; Lei 8.429/1992, Art. 12; Decreto 11.129/2022

Action

Fine

Status of proceedings

final

Sector

Food and agriculture

Mitigating circumstances

Credit was given for returning the advantage (1%), cooperation (1%), voluntary admission (1.5%) and an applied compliance programme (2.1%).

Liability of senior managers

Tolerance or knowledge by management (3%) and the concurrence of several offences (3%) were aggravating factors.

Original amount 22,040,373.16 BRL, converted at the ECB reference rate of 5 May 2025.

Checked against the official source on 3 Oct 2026 · Direct link

A Brazilian food group undertook, in a leniency agreement with the CGU (Office of the Comptroller General) and the AGU (Office of the Attorney General), to pay BRL 583,977,360.48 in five annual instalments from 2023 because, according to the confidential Annex I, it had paid undue advantages to public officials or third parties connected to them. The amount comprises disgorgement of unlawful advantages (BRL 314,875,384.01), a fine under Lei 8.429/1992 (BRL 9,173,587.96) and a fine under the Anti-Corruption Act Lei 12.846/2013 (BRL 259,928,388.50); without the agreed reductions it would have been BRL 1,170,184,567.12. According to the agreement, the conduct did not concern federal procurement and no damage to the public purse had been established by the time of signing.

Authority / court

Controladoria-Geral da União (CGU) und Advocacia-Geral da União (AGU)

Area of law

Bribery and corruption · Bribery of public officials

Legal basis

Lei 12.846/2013, Arts. 16 und 17; Lei 8.429/1992; Decreto 11.129/2022, Art. 33; Instrução Normativa CGU/AGU 2/2018

Action

Disgorgement of profits

Status of proceedings

final

Sector

Food and agriculture

Employees

10,000 or more

Mitigating circumstances

Cooperation (1%), spontaneous disclosure before proceedings (1%) and an applied compliance programme (2.21%) were credited; the anti-corruption fine was reduced by 63.33% and the disgorgement by 30%.

Liability of senior managers

Tolerance or knowledge by senior management was applied as an aggravating factor at 2.25%.

Original amount 583,977,360.48 BRL, converted at the ECB reference rate of 28 Dec 2022.

Checked against the official source on 7 Oct 2026 · Company name anonymised since 28 Dec 2024 · Direct link