Who was sanctioned, and for what?

Bayer S.A. concluded a settlement (Termo de Compromisso de Cessação) with the Conselho Administrativo de Defesa Econômica (CADE, Brazilian competition authority) in proceedings concerning the exchange of competitively sensitive information between employers in the consumer goods sector with possible effects on the Brazilian labour market. The company admitted its participation, undertook to cease the conduct and to cooperate with the investigation, and allegedly pays 5,003,188.80 BRL to the Fund for Diffuse Rights (FDD). In the same proceedings, 3M do Brasil concluded a separate settlement of allegedly 4,454,414.82 BRL. The amount and the facts have not been confirmed against the primary source.

Authority / court

Conselho Administrativo de Defesa Econômica (CADE), Tribunal Administrativo

Area of law

Competition law · Cartels and collusion

Legal basis

Lei nº 12.529/2011 (Lei de Defesa da Concorrência), Termo de Compromisso de Cessação

Action

Other

Status of proceedings

final

Sector

Chemicals and pharmaceuticals

Employees

10,000 or more

Published

6 May 2025

Original amount 5,003,188.8 BRL, converted at the ECB reference rate of 28 Apr 2025.

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

The CADE Tribunal convicted five companies of a cartel in public tenders for medicines and in private pharmaceutical sales which, according to CADE, operated at least from 2007 to 2011 in states including Minas Gerais, São Paulo, Bahia and Pernambuco; besides direct price-fixing between manufacturers, some manufacturers facilitated collusion between distributors (hub-and-spoke cartel). The fines on the companies total 45,328,574.05 BRL (Hipolabor Farmacêutica 15,741,025.02; Sanval 12,191,091.60; Comercial Cirúrgica Rioclarense 11,952,437.72; Rhamis Distribuidora Farmacêutica 3,585,615.18; Macromed 1,858,404.53 BRL). Proceedings against several other parties were closed for lack of evidence or because settlements had been fulfilled. The amount and the facts have not been confirmed against the primary source.

Authority / court

Conselho Administrativo de Defesa Econômica (CADE), Tribunal Administrativo

Area of law

Competition law · Cartels and collusion

Legal basis

Art. 20 I–IV i. V. m. Art. 21 I, II, III, VIII Lei nº 8.884/1994, entsprechend Art. 36 I–IV, § 3 I a, c, d Lei nº 12.529/2011; Bemessung nach Art. 37 Lei nº 12.529/2011

Action

Fine

Status of proceedings

unknown

Sector

Chemicals and pharmaceuticals

Liability of senior managers

Measures against individuals are not set out here.

Published

12 Dec 2024

Original amount 45,328,574.05 BRL, converted at the ECB reference rate of 11 Dec 2024.

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

The Controladoria-Geral da União (CGU, Office of the Comptroller General) imposed on a pharmaceutical distributor, which now trades under a different name, a fine of BRL 3,879,251.35, extraordinary publication of the decision and a declaration of unsuitability for public contracts (declaração de inidoneidade). According to the final report, in the Ministry of Health's planned purchase of 20 million doses of a Covid-19 vaccine the company submitted a document that the vaccine manufacturer later described as false, as well as pro forma invoices that did not match the contract terms. On a request for reconsideration (pedido de reconsideração) the CGU reduced the fine to BRL 2,586,167.56 on 5 May 2025 and shortened the posting period for the publication from 75 to 60 days; the declaration of unsuitability remained in place.

Authority / court

Controladoria-Geral da União (CGU)

Area of law

Bribery and corruption

Legal basis

Lei nº 12.846/2013, Art. 5 IV b und d, Art. 6; Lei nº 8.666/1993, Art. 87 IV und Art. 88 III

Action

Fine

Status of proceedings

reduced

Sector

Chemicals and pharmaceuticals

Mitigating circumstances

Following the request for reconsideration, the CGU reduced the fine from BRL 3,879,251.35 to BRL 2,586,167.56.

Published

15 Jan 2024

Original amount 2,586,167.56 BRL, converted at the ECB reference rate of 9 Jan 2024.

Checked against the official source on 7 Oct 2026 · Company name anonymised since 9 Jan 2026 · Direct link

A US chemical and technology company undertook, in 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), to pay BRL 638,046,365.87 (equivalent to USD 120,828,384.25) because, in connection with contracts with a state-controlled oil company, it had made improper payments for the benefit of public officials through intermediary companies. According to the annexes, USD 75,817,531.39 relates to disgorgement of profit and USD 10,601,873.74 to presumed damage (bribes) in favour of the oil company, while USD 5,708,217.91 is the fine under the Anti-Corruption Act (Lei 12.846/2013) and USD 28,700,761.19 the fine under the Administrative Improbity Act (Lei 8.429/1992). According to its own statement, the company concluded agreements with the Federal Public Prosecutor's Office (MPF), the US Department of Justice and the SEC on the same day.

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

Action

Disgorgement of profits

Status of proceedings

final

Sector

Chemicals and pharmaceuticals

Mitigating circumstances

Credit was given for remediation of damage (1%), cooperation (1%), voluntary admission (2%) and an applied compliance programme (3.06%).

Liability of senior managers

The fine calculation treated tolerance or knowledge by senior management as an aggravating factor at the maximum rate of 3%.

Original amount 638,046,365.87 BRL, converted at the ECB reference rate of 19 Dec 2022.

Checked against the official source on 7 Oct 2026 · Company name anonymised since 19 Dec 2024 · Direct link