Who was sanctioned, and for what?

Carioca Christiani-Nielsen Engenharia S.A. concluded a single settlement (Termo de Compromisso de Cessação) with the Conselho Administrativo de Defesa Econômica (CADE, Brazilian competition authority) covering four proceedings concerning alleged collusion in public tenders for infrastructure projects (metro, airports operated by Infraero, the rail company CPTM and the transport authority DNIT). The company admitted its participation, allegedly pays 6,134,676.92 BRL in instalments to the Fund for Diffuse Rights (FDD) and waives court and administrative disputes on these matters. Together with the company’s earlier settlements with CADE, its contributions exceed 90 million BRL.

Authority / court

Conselho Administrativo de Defesa Econômica (CADE)

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

Construction and real estate

Published

22 Sep 2026

Original amount 6,134,676.92 BRL, converted at the ECB reference rate of 22 Sep 2026.

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

The Tribunal of the Conselho Administrativo de Defesa Econômica (CADE, Brazilian competition authority) unanimously found that Cervejaria Petrópolis had taken control of the oil producer Imcopa before the legally required notification (gun jumping) and imposed a fine of 1,382,418.22 BRL. According to the investigation, the acquisition was completed on 19 March 2024 but notified only on 9 April 2024; CADE itself cleared the transaction without conditions in April 2024. The argument that the change of control resulted from court decisions in the judicial reorganisation proceedings (recuperação judicial) did not persuade the authority. 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 · Merger control

Legal basis

Art. 88 § 3 Lei nº 12.529/2011 (Lei de Defesa da Concorrência)

Action

Fine

Status of proceedings

unknown

Sector

Food and agriculture

Published

8 Sep 2026

Original amount 1,382,418.22 BRL, converted at the ECB reference rate of 2 Sep 2026.

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

The Agência Nacional de Proteção de Dados (ANPD, Brazilian data protection authority) imposed three fines totalling 153,769,671.33 BRL on ByteDance Brasil Tecnologia Ltda., which operates TikTok in Brazil (63,176,686.67 BRL each for breaches of Art. 7 and Art. 6 VIII LGPD, and 27,416,297.99 BRL for Art. 6 X LGPD). According to the decision, data of children and adolescents were processed without a valid legal basis both in the feed available without registration and when accounts were created, and effective preventive and accountability measures were lacking. The authority also ordered the deletion of data of registered adolescents aged 13 to 18 whose legal representation is not regularised within 60 working days, backed by a daily penalty of 137,081.49 BRL for each day of delay.

Authority / court

Agência Nacional de Proteção de Dados (ANPD), Superintendência de Fiscalização

Area of law

Data protection

Legal basis

Art. 6 VIII, Art. 6 X und Art. 7 LGPD (Lei nº 13.709/2018); Sanktionen nach Art. 52 LGPD; Resolução CD/ANPD nº 4/2023 (Regulamento de Dosimetria)

Action

Fine

Status of proceedings

unknown

Sector

Media and online platforms

Employees

10,000 or more

Published

25 Aug 2026

Original amount 153,769,671.33 BRL, converted at the ECB reference rate of 24 Aug 2026.

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

The Comitê de Decisão de Processo Administrativo Sancionador (COPAS, sanctions decision committee) of the Banco Central do Brasil (Brazilian central bank) fined Banco Genial S.A. a total of BRL 21,560,000.00: BRL 4,200,000.00 for inadequate anti-money laundering policies, procedures and controls, BRL 8,920,000.00 for failing to verify the credentials of foreign exchange clients and BRL 8,440,000.00 for failing to file suspicious activity reports with the financial intelligence unit Coaf in the proper form and on time. According to the case documents, the reporting charge concerned 1,364 foreign exchange transactions for the acquisition of virtual assets with five clients between November 2020 and October 2021, totalling USD 744,341,982.45.

Authority / court

Banco Central do Brasil (Comitê de Decisão de Processo Administrativo Sancionador – COPAS)

Area of law

Money laundering and terrorist financing · Customer due diligence

Legal basis

Lei nº 9.613/1998, Art. 10 III, Art. 11 und 12; Lei nº 13.506/2017; Circular BCB nº 3.978/2020; Resolução CMN nº 3.568/2008

Action

Fine

Status of proceedings

unknown

Sector

Financial services and insurance

Liability of senior managers

Measures against individuals are not set out here.

Original amount 21,560,000 BRL, converted at the ECB reference rate of 12 Aug 2026.

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

The BCB (central bank) sanctions committee COPAS imposed a fine of BRL 2,576,000.00 on Lebes Financeira S.A. – Sociedade de Crédito, Financiamento e Investimento because from January 2022 to March 2023 it engaged in prohibited credit transactions with a related company: its banking correspondent retained collected loan instalments, and the arrears reached BRL 147m at the end of November 2022, or 207.66% of adjusted equity against a limit of 10%. In addition there was a BRL 20m loan routed through a third company. The decision is not final.

Authority / court

Banco Central do Brasil (Comitê de Decisão de Processo Administrativo Sancionador – COPAS)

Area of law

Capital markets and financial supervision · Organisational requirements

Legal basis

Lei 13.506/2017, Art. 3 II; Lei 4.595/1964, Art. 34 § 3 V d und § 4 I; Resolução CMN 4.693/2018, Arts. 5, 6 und 7 II

Action

Fine

Status of proceedings

under appeal

Sector

Financial services and insurance

Liability of senior managers

Measures against individuals are not set out here.

Original amount 2,576,000 BRL, converted at the ECB reference rate of 12 Aug 2026.

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

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

The Controladoria-Geral da União (CGU, Office of the Comptroller General) imposed on RSX Informática Ltda. a fine of BRL 8,794,574.67, extraordinary publication of the decision and a three-year ban on tendering for and contracting with the Federal Union, including removal from the supplier register SICAF. The case concerned fraud in a tender (pregão nº 5/2017) of the former Ministry of National Integration and in the resulting contracts; through the price registration agreement, other federal bodies, including the social security institute INSS with a software contract, contracted with the company without holding their own tender.

Authority / court

Controladoria-Geral da União (CGU)

Area of law

Bribery and corruption

Legal basis

Lei nº 12.846/2013, Art. 5 IV d, Art. 6 I und II; Lei nº 10.520/2002, Art. 7

Action

Fine

Status of proceedings

unknown

Sector

Telecoms, IT and software

Published

10 Jul 2026

Original amount 8,794,574.67 BRL, converted at the ECB reference rate of 9 Jul 2026.

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

IRB-Brasil Resseguros S.A. concluded a Termo de Compromisso (settlement in sanction proceedings) with the CGU and allegedly pays a fine of BRL 6,317,473.41 because the company had hindered the investigative and supervisory activity of the insurance supervisor SUSEP (Art. 5 V Lei 12.846/2013). The fine equals the statutory minimum of 0.1% of gross revenue (BRL 6,509,921.81) less BRL 192,448.40 already paid in SUSEP proceedings over inconsistent reporting. Extraordinary publication was waived, and the proceedings are thereby closed.

Authority / court

Controladoria-Geral da União (CGU)

Area of law

Bribery and corruption

Legal basis

Lei 12.846/2013, Art. 5 V, Art. 6 I; Decreto 11.129/2022, Art. 25 § 2; Portaria Normativa CGU 155/2024

Action

Fine

Status of proceedings

final

Sector

Financial services and insurance

Repeat case

no

Mitigating circumstances

Credit was given for a compliance programme (3.6%), the absence of proof of advantage or damage (1%) and settlement-related reductions for cooperation and admission; fines already paid to SUSEP were deducted.

Published

3 Jul 2026

Original amount 6,317,473.41 BRL, converted at the ECB reference rate of 2 Jul 2026.

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

In cartel proceedings, the CADE Tribunal fined ten suppliers of electronic products, while the signatories of a 2014 leniency agreement (Agilent and Keysight) and one company that had fulfilled a settlement were not sanctioned. The fines on the companies initially totalled 8,362,138.05 BRL; in the virtual deliberation procedure the plenary, deciding on motions for clarification (embargos) on 17 August 2026, reduced of its own motion the fines on Datasonic (from 4,329,605.69 to 856,937.12 BRL) and D.T.I. (from 1,021,750.18 to 265,406.99 BRL), leaving 4,133,126.29 BRL. The session minutes do not identify the market concerned. 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

Action

Fine

Status of proceedings

reduced

Sector

Manufacturing and mechanical engineering

Liability of senior managers

Measures against individuals are not set out here.

Published

8 Jul 2026

Original amount 4,133,126.29 BRL, converted at the ECB reference rate of 1 Jul 2026.

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

The Tribunal of the Conselho Administrativo de Defesa Econômica (CADE, Brazilian competition authority) unanimously fined Denso Corporation 100,787,523.05 BRL for taking part in an international cartel in wire harnesses and electrical and electronic automotive components with effects in Brazil. According to the rapporteur’s vote, Denso took part in price fixing, the allocation of projects, geographic market sharing and the exchange of sensitive information roughly between 2000 and 2008. For other participants the proceedings ended through leniency, settlements or for lack of evidence; CADE dismissed Denso’s motion for clarification (embargos) in August 2026. 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)

Action

Fine

Status of proceedings

unknown

Sector

Automotive

Employees

10,000 or more

Published

10 Jun 2026

Original amount 100,787,523.05 BRL, converted at the ECB reference rate of 10 Jun 2026.

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

The CADE Tribunal convicted three companies of a buyer cartel in the purchase of animal residues in Rio Grande do Sul: according to CADE, rendering plants and haulage companies divided collection points among themselves, exchanged sensitive information and obstructed competitors outside the arrangement. Frigorífico Cason received 5,937,915.73 BRL and the two ASM companies jointly 455,419.65 BRL (6,393,335.38 BRL in total); proceedings against several other parties were closed because settlements had been fulfilled or for lack of evidence. 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

Action

Fine

Status of proceedings

unknown

Sector

Food and agriculture

Liability of senior managers

Measures against individuals are not set out here.

Published

29 May 2026

Original amount 6,393,335.38 BRL, converted at the ECB reference rate of 27 May 2026.

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 sanctions committee COPAS of the Banco Central do Brasil (central bank) imposed fines totalling BRL 16,280,000.00 on Banco Topázio S.A.: BRL 4,560,000.00 because its monitoring system contained no rules for foreign exchange transactions to buy and sell virtual assets, BRL 3,280,000.00 because suspicious transactions were not reported, or reported late, to the financial intelligence unit Coaf (including BRL 3.05bn from one client), and BRL 8,440,000.00 because the bank had not verified the qualification of foreign exchange clients. In addition, for two years it may not carry out over-the-counter foreign exchange transactions for virtual assets in which the client acts as an unauthorised intermediary for third parties. The decision is not final.

Authority / court

Banco Central do Brasil (Comitê de Decisão de Processo Administrativo Sancionador – COPAS)

Area of law

Money laundering and terrorist financing · Suspicious activity reports

Legal basis

Lei 9.613/1998, Art. 10 III, Art. 11 II, Art. 12 II und § 2 II und IV; Circular BCB 3.978/2020, Arts. 38, 39 und 48; Lei 13.506/2017, Art. 3 XVII, Art. 5 II und IV

Action

Fine

Status of proceedings

under appeal

Sector

Financial services and insurance

Liability of senior managers

Measures against individuals are not set out here.

Original amount 16,280,000 BRL, converted at the ECB reference rate of 11 May 2026.

Checked against the official source on 3 Oct 2026 · 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

The CADE Tribunal found that the Libra league, as a joint venture of clubs for the joint commercialisation of broadcasting and commercial rights, was notifiable and had been implemented before clearance, and approved a settlement (Acordo em APAC) with Libra and Flamengo, Palmeiras, Santos, São Paulo and Grêmio with an alleged pecuniary contribution of 559,267.26 BRL. The parties must notify the transactions already completed within 60 days and report changes to their commercialisation structures for three years; for the rival league FFU (formerly LFU) no infringement was found because the turnover thresholds were not met. 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 · Merger control

Legal basis

Art. 88 § 3 Lei nº 12.529/2011

Action

Other

Status of proceedings

final

Sector

Media and online platforms

Published

11 Feb 2026

Original amount 559,267.26 BRL, converted at the ECB reference rate of 11 Feb 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

The Controladoria-Geral da União (CGU, Office of the Comptroller General) imposed on Linkcon Ltda. a fine of BRL 21,521,878.64, extraordinary publication of the decision and a two-year ban on tendering for and contracting with the Federal Union. According to the final report, an electronic tender of the port company Companhia Docas do Rio de Janeiro (PE 17/2016) and the resulting price registration agreement were steered in the company's favour through simulated price surveys; it also submitted a false document to be classified as a small business (EPP). The CGU rejected the request for reconsideration on 30 July 2026. The amount and the facts have not been confirmed against the primary source.

Authority / court

Controladoria-Geral da União (CGU)

Area of law

Bribery and corruption

Legal basis

Lei nº 12.846/2013, Art. 5 IV a, Art. 6 I und II; Lei nº 10.520/2002, Art. 7

Action

Fine

Status of proceedings

final

Sector

Telecoms, IT and software

Published

12 Jan 2026

Original amount 21,521,878.64 BRL, converted at the ECB reference rate of 9 Jan 2026.

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

The Ministério do Trabalho e Emprego (MTE, Ministry of Labour and Employment) entered the sugar mill Renuka Vale do Ivaí S.A. (in judicial reorganisation) in the register of employers that have subjected workers to conditions analogous to slavery (Cadastro de Empregadores, the ‘Lista Suja’). The entry is based on a 2025 labour inspection at the sugar cane mill in São Pedro do Ivaí (Paraná) involving 57 workers; the final administrative decision was taken on 22 December 2025 and the entry was made in the update of 6 April 2026.

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 (Cadastro de Empregadores)

Action

Other

Status of proceedings

final

Sector

Food and agriculture

Published

6 Apr 2026

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

The Tribunal of the Conselho Administrativo de Defesa Econômica (CADE, Brazilian competition authority) unanimously convicted the manufacturers Elo Sistemas Eletrônicos, FAE Sistemas de Medição (formerly Fae Ferragens e Aparelhos Elétricos) and Dowertech da Amazônia (now Wasion da Amazônia) of a cartel in electricity meters, in which between 2005 and 2014 prices in public and private tenders were agreed, the market was shared and monitored and cover bids were submitted. The companies received fines of 54,238,824.03 BRL, 15,167,886.53 BRL and 3,196,631.43 BRL. The case was triggered by a leniency application in 2014; in the same session CADE approved four further settlements worth around 15.5 million 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)

Action

Fine

Status of proceedings

unknown

Sector

Manufacturing and mechanical engineering

Liability of senior managers

Measures against individuals are not set out here.

Published

10 Dec 2025

Original amount 72,603,341.99 BRL, converted at the ECB reference rate of 10 Dec 2025.

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

The CADE Tribunal approved a cease-and-desist settlement (TCC) with Rinnai Brasil in proceedings concerning the market for gas water heaters: according to the General Superintendence, the company had abused its dominant position by imposing minimum advertised prices on resellers, which acted as minimum advertised pricing in physical retail and in practice as resale price maintenance online. Rinnai undertook to cease the practices, to take precautions against new infringements and allegedly to pay 11,215,319.31 BRL to the Fund for Diffuse Rights (FDD). 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 · Abuse of market power

Legal basis

Lei nº 12.529/2011 (Termo de Compromisso de Cessação)

Action

Other

Status of proceedings

final

Sector

Manufacturing and mechanical engineering

Published

11 Dec 2025

Original amount 11,215,319.31 BRL, converted at the ECB reference rate of 10 Dec 2025.

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

On 22 October 2025 the CADE Tribunal approved, in a single block, five cease-and-desist settlements (Termos de Compromisso de Cessação, TCC) with banks and allegedly set the following pecuniary contributions: BofA Securities Inc. 33,010,207.04 BRL, Nomura International plc 32,145,917.76 BRL, Standard Chartered Bank 11,544,947.78 BRL, Credit Suisse AG 1,582,051.57 BRL and MUFG Bank 714,782.33 BRL, together 78,997,906.48 BRL. The session minutes do not state the subject of the proceedings; all five banks are, however, among the parties whose conviction the General Superintendence had recommended in April 2025 in the proceedings on the offshore foreign-exchange cartel (according to CADE, collusion on the prices of FX transactions, exchange of sensitive information and disadvantaging other market participants such as brokers). 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 (Termo de Compromisso de Cessação)

Action

Other

Status of proceedings

final

Sector

Financial services and insurance

Employees

10,000 or more

Liability of senior managers

Measures against individuals are not set out here.

Published

30 Oct 2025

Original amount 78,997,906.48 BRL, converted at the ECB reference rate of 22 Oct 2025.

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

The MTE (Ministry of Labour and Employment) entered Joca Participações S/A 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 at Fazenda Aroeira in Getulina (SP) involving 25 affected workers; the administrative finding was issued on 22 October 2025.

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

Food and agriculture

Published

6 Apr 2026

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

The Controladoria-Geral da União (CGU, Office of the Comptroller General) fined Bulls Holding Investments Company S.A. BRL 387,431,733.02 and RS Investimentos S/A BRL 121,380,000.00 (BRL 508,811,733.02 in total) and ordered extraordinary publication of the decision for each. According to the final report, the companies had submitted to the insurance supervisor SUSEP bids to take over the pension association APLUB, which was under special intervention, backed by inadequate and in part apparently forged documents, thereby interfering with SUSEP's supervisory activity; RS Investimentos was additionally sanctioned for supporting Bulls Holding's acts. The amount and the facts have not been confirmed against the primary source.

Authority / court

Controladoria-Geral da União (CGU)

Area of law

Bribery and corruption

Legal basis

Lei nº 12.846/2013, Art. 5 II und V, Art. 6 I und II, Art. 14

Action

Fine

Status of proceedings

unknown

Sector

Financial services and insurance

Liability of senior managers

Measures against individuals are not set out here.

Published

2 Oct 2025

Original amount 508,811,733.02 BRL, converted at the ECB reference rate of 30 Sep 2025.

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

Seatrium Ltd., Jurong Shipyard Pte. Ltd. (both Singapore) and Estaleiro Jurong Aracruz 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 undue advantages given to public officials or politicials and persons connected to them, and undue advantages obtained in contracts with the public administration. The companies allegedly acknowledged a debt of BRL 728,933,258.58, payable within 60 days; according to the companies, they have also negotiated agreements with the Federal Public Prosecutor's Office (MPF) and Singapore's Attorney-General's Chambers. 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, III und IV d, Art. 16; Lei nº 8.666/1993, Art. 88 II und III; Lei nº 8.429/1992

Action

Fine

Status of proceedings

final

Sector

Manufacturing and mechanical engineering

Mitigating circumstances

Commitment by the CGU and AGU to avoid double payments in relation to an agreement with the MPF; obligation to improve the integrity programme.

Original amount 728,933,258.58 BRL, converted at the ECB reference rate of 30 Jul 2025.

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

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 two car dealers of gun jumping: in March 2015 Navesa had acquired tangible and intangible assets from Renauto for operating Renault dealerships in Goiânia without obtaining clearance for the notifiable transaction. Although the Tribunal had ordered notification in August 2023, the parties filed the form only in November 2024; a fine totalling 5,360,560.00 BRL, payable within 30 days, was imposed. 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 · Merger control

Legal basis

Art. 88 § 3 Lei nº 12.529/2011; Art. 12 II a Resolução CADE nº 24/2019

Action

Fine

Status of proceedings

unknown

Sector

Automotive

Published

9 Apr 2025

Original amount 5,360,560 BRL, converted at the ECB reference rate of 9 Apr 2025.

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

The CADE Tribunal convicted the federal council of physiotherapists and occupational therapists because, through resolutions, rulings and annually updated reference tables, it had set binding minimum prices for the services of members of the profession and thereby encouraged uniform market conduct. In addition to a fine of 3,103,583.65 BRL, COFFITO must refrain from binding price tables, remove all references to them from its websites (penalty of 5,000.00 BRL per day) and publish the decision on its website and social media; proceedings against the regional council for the 15th region are suspended owing to a settlement. 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 und 39 (Nebenanordnungen)

Action

Fine

Status of proceedings

unknown

Sector

Healthcare

Published

10 Apr 2025

Original amount 3,103,583.65 BRL, converted at the ECB reference rate of 9 Apr 2025.

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

The CVM ordered Regen Serviços Fiduciários Ltda. to pay a fine of BRL 255,000.00 because its internal controls failed and it repeatedly submitted incorrect information to the authority on the liquidity of the investment funds it administered (Art. 19 Instrução CVM 558 until 30 June 2021, thereafter Art. 22 Resolução CVM 21). The company had not submitted a defence; an appeal with suspensive effect to the CRSFN was available against the decision.

Authority / court

Comissão de Valores Mobiliários (CVM)

Area of law

Capital markets and financial supervision · Organisational requirements

Legal basis

Instrução CVM 558/2015, Art. 19; Resolução CVM 21/2021, Art. 22

Action

Fine

Status of proceedings

unknown

Sector

Financial services and insurance

Published

8 Apr 2025

Original amount 255,000 BRL, converted at the ECB reference rate of 8 Apr 2025.

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

The MTE (Ministry of Labour and Employment) entered Gerezim Mineração Ltda. on 6 October 2025 in the register of employers that have kept workers in conditions akin to slavery (the ‘Lista Suja’). The entry followed a labour inspection in 2024 at Fazenda Pindaíba in Bocaiúva (MG) involving 34 affected workers; the administrative finding was issued on 4 April 2025.

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

Other

Published

6 Oct 2025

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

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

Qualicorp Consultoria e Corretora de Seguros S.A. acknowledged, in a leniency agreement with the CGU and the AGU, that it had paid an economic advantage to a public official whose action or omission was in the company's interest. It allegedly pays BRL 44,485,434.29 as a fine plus disgorgement: BRL 27,803,396.43 as disgorgement of the advantage obtained and a fine of BRL 16,682,037.86 under Lei 12.846/2013 (40% reduction), both indexed to IPCA up to December 2024. The agreement extends to other companies of the Qualicorp group. 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, Art. 19 I; Lei 8.429/1992; Decreto 11.129/2022

Action

Fine

Status of proceedings

final

Sector

Financial services and insurance

Mitigating circumstances

Credit was given for returning the advantage (1%), cooperation (1.5%) and voluntary admission (2%); no compliance programme was taken into account. The fine equals the statutory minimum of the advantage obtained, then reduced by 40%.

Liability of senior managers

Tolerance or knowledge by senior management was applied as an aggravating factor at the maximum rate of 3%.

Original amount 44,485,434.29 BRL, converted at the ECB reference rate of 17 Mar 2025.

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

The board of the Comissão de Valores Mobiliários (CVM, Brazilian Securities and Exchange Commission) fined the fund administrator Intra DTVM Ltda. BRL 1,200,000.00 for filing mandatory periodic information on the investment funds it administered late or not at all (Art. 59 Instrução CVM 555). According to the charges, 121 mandatory documents for 12 of the 19 funds it administered were missing at the end of the 2020 financial year; the company was acquitted of the charge of breaching its duty of diligence on a tied vote, since in that event the view more favourable to the accused prevails. An appeal against the decision is pending before the Conselho de Recursos do Sistema Financeiro Nacional (CRSFN, financial system appeals board). The decision is not final.

Authority / court

Comissão de Valores Mobiliários (CVM)

Area of law

Capital markets and financial supervision · Disclosure and reporting obligations

Legal basis

Instrução CVM nº 555/2014, Art. 59

Action

Fine

Status of proceedings

under appeal

Sector

Financial services and insurance

Published

18 Mar 2025

Original amount 1,200,000 BRL, converted at the ECB reference rate of 11 Mar 2025.

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

The Controladoria-Geral da União (CGU, Office of the Comptroller General) imposed on the Associação da Irmandade da Santa Casa de Misericórdia de Pacaembu, an association operating as a healthcare social organisation (Organização Social), a fine of BRL 47,391,386.87, extraordinary publication of the decision and a declaration of unsuitability for public contracts. According to the final report, the association rigged the selection procedure for managing the Hangar field hospital in Belém (Pará), committed fraud in performing the management contract for a regional hospital in Belém and used front persons and companies to conceal its real interests.

Authority / court

Controladoria-Geral da União (CGU)

Area of law

Bribery and corruption

Legal basis

Lei nº 12.846/2013, Art. 5 III und IV b und d, Art. 6, Art. 14; Lei nº 8.666/1993, Art. 87 IV und Art. 88 II und III

Action

Fine

Status of proceedings

final

Sector

Healthcare

Liability of senior managers

Measures against individuals are not set out here.

Published

28 Jan 2025

Original amount 47,391,386.87 BRL, converted at the ECB reference rate of 23 Jan 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 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

The Comissão de Valores Mobiliários (CVM, securities regulator) ordered Florim Consultoria Ltda. (formerly Silverado Gestão e Investimentos Ltda.) to pay BRL 244,979,397.58 for fraudulent transactions in managing three receivables funds (FIDC). For deficient controls as administrators or custodians of the funds, Santander Caceis Brasil DTVM S.A. received BRL 2,720,000.00, Gradual CCTVM S.A. – Massa Falida BRL 1,700,000.00, BNY Mellon Serviços Financeiros DTVM S.A. BRL 1,200,000.00 and Deutsche Bank S.A. – Banco Alemão BRL 500,000.00, totalling BRL 251,099,397.58 against companies. BNY Mellon, Gradual, Santander Caceis and Deutsche Bank were acquitted of certain charges.

Authority / court

Comissão de Valores Mobiliários (CVM)

Area of law

Capital markets and financial supervision · Market abuse and insider dealing

Legal basis

Instrução CVM 08/1979, Ziff. I i. V. m. II c; Instrução CVM 356/2001, Art. 8 § 3 I, Art. 38 III und IV, Art. 39 II und III i. V. m. § 4

Action

Fine

Status of proceedings

unknown

Sector

Financial services and insurance

Liability of senior managers

Measures against individuals are not set out here.

Published

16 Oct 2024

Original amount 251,099,397.58 BRL, converted at the ECB reference rate of 15 Oct 2024.

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