Compliance Radar
Who was sanctioned, and for what?
Fines, court rulings and incidents from Europe, North America, Latin America, Asia-Pacific and Middle East: 1,929 cases from 40 jurisdictions, each with an official source and checked against that source before publication. Filter by country, area of law and sector. Click a chart to drill down one level.
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Where?
by authority- Controladoria-Geral da União (CGU) und Advocacia-Geral da União (AGU) €69.9m 100 % · 1 case
What for?
by area of lawAll areas of law
Who?
by companyWhen?
per quarter, by date of decision| Period | Cases | Total |
|---|---|---|
| Q4 2023 | 0 | – |
| Q1 2024 | 0 | – |
| Q2 2024 | 0 | – |
| Q3 2024 | 0 | – |
| Q4 2024 | 0 | – |
| Q1 2025 | 1 | €69.9m |
| Q2 2025 | 0 | – |
| Q3 2025 | 0 | – |
| Q4 2025 | 0 | – |
| Q1 2026 | 0 | – |
| Q2 2026 | 0 | – |
| Q3 2026 | 0 | – |
| Q4 2026 | 0 | – |
1 case
28 Mar 2025 Trafigura Beheer B.V.Trafigura Beheer: leniency agreement with CGU and AGU for BRL 435.4m €69.9m
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.
In corruption cases involving several countries, double payments can be avoided through coordinated agreements with all the authorities involved.
Payments to public officials and use of intermediaries
- 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.
- Acordo de Leniência CGU/AGU – Trafigura Beheer B.V. (Processo 00190.100002/2022-21, SEI 3569333) Decision of an authority
- CGU: Acordos de leniência celebrados (Liste mit Unternehmen und Beträgen) Official register or notice
Checked against the official source on 3 Oct 2026 · Direct link