Who was sanctioned, and for what?

Trafigura Beheer B.V. 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) in which it admitted paying undue advantages to public officials and using front persons to conceal its interests. It allegedly pays BRL 435,410,672.26: BRL 153,710,689.11 within ten days (the conversion of USD 26,829,346; under its agreement with the US Department of Justice on a fine of USD 80,488,040, this part of the US fine may be offset by the payment to the Brazilian authorities) and BRL 281,699,983.15 (the conversion of USD 49,169,165.53) as the remaining balance. 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 nº 12.846/2013, Art. 5 I und III, Art. 16; Lei nº 8.429/1992; Decreto nº 11.129/2022

Action

Fine

Status of proceedings

final

Sector

Energy and utilities

Mitigating circumstances

Coordination with the US proceedings so that part of the Brazilian payment can be credited against the US fine; obligation to improve the integrity programme under CGU monitoring for 36 months.

Original amount 435,410,672.26 BRL, converted at the ECB reference rate of 28 Mar 2025.

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

The CADE Tribunal convicted three petrol station companies because in 2017 they had divided the lots of municipal fuel tenders in Coronel Vivida (Paraná) among themselves in advance and had also coordinated retail pump prices. The fines on the companies initially totalled 43,953,905.42 BRL (Comércio de Combustíveis Stang 25,801,726.15; a further petrol station company 9,406,784.68; Pato Comércio de Combustíveis 8,745,394.59 BRL). On motions for clarification (embargos) the Tribunal reduced, on 1 July 2026, the fines on Stang to 4,615,849.76 BRL and on Pato to 1,090,682.28 BRL owing to a subsequently arising fact relevant to the calculation, leaving 15,113,316.72 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; Art. 38 VI (Handelsverbot für natürliche Personen)

Action

Fine

Status of proceedings

reduced

Sector

Energy and utilities

Liability of senior managers

Measures against individuals are not set out here.

Published

13 May 2026

Original amount 15,113,316.72 BRL, converted at the ECB reference rate of 13 May 2026.

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

The Ministry of Labour and Employment (MTE) again entered Centroálcool S/A (em recuperação judicial) on 6 April 2026 in the register of employers that have kept workers in conditions akin to slavery (the ‘Lista Suja’). The entry is based on a labour inspection in 2025 involving 58 affected workers and the administrative finding of 8 September 2025. The company is already on the list with two entries from a 2023 inspection in Inhumas (GO) (53 and 5 workers, finding of 28 February 2024).

Authority / court

Ministério do Trabalho e Emprego (MTE), Inspeção do Trabalho

Area of law

Supply chain and human rights · Forced and child labour

Legal basis

Portaria Interministerial MTE/MDHC/MIR nº 18/2024, Art. 2

Action

Other

Status of proceedings

unknown

Sector

Energy and utilities

Repeat case

yes

Published

6 Apr 2026

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

The US company Freepoint Commodities LLC admitted, in a leniency agreement with the CGU and the AGU, to having paid undue advantages to public officials through intermediaries (Art. 5 I and III Lei 12.846/2013) and allegedly pays BRL 108,710,739.68 as a fine plus disgorgement. According to Annex III, BRL 60,919,037.14 is the fine payable to the Union (after a 67% reduction) and BRL 47,791,702.54 is disgorgement. Damages to Petrobras of BRL 22,542,907.62 are set out only in the text. The agreement also stated a total of BRL 131,253,647.32 (USD 22,744,839.85); the two centavos by which that total exceeds the fine, the disgorgement and the damages are not smoothed. If the company resumes business in Brazil within five years, it must adapt its compliance programme to Brazilian law and report to the CGU. 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. 5 I und III, Art. 6 I, Arts. 16, 17 und 19 I; Lei 8.429/1992; Decreto 11.129/2022

Action

Fine

Status of proceedings

final

Sector

Energy and utilities

Mitigating circumstances

Credit was given for remediation of damage (1%), cooperation (1.5%) and voluntary admission (2%); no reduction was granted for a compliance programme.

Liability of senior managers

Tolerance or knowledge by management was applied as an aggravating factor at 2.5%.

Original amount 108,710,739.68 BRL, converted at the ECB reference rate of 14 Nov 2024.

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