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The Brazil Clean Company Act

By Ellen Zimiles , Jay Perlman

In August 2013, Brazilian President Dilma Rousseff signed Brazil’s Clean Company Act (BCCA), which becomes effective as of January 29, 2014.

The BCCA is the latest example of the globalization of anti-bribery and corruption regulation and will impact any organization conducting business in the country. Brazil has been a member of the Organization for Economic Cooperation and Development’s (“OECD”) Anti-Bribery Convention since 2000 and the United Nations Convention against Corruption since 2005, the law comes over five years after the OECD’s 2007 recommendation that Brazil strengthen its corporate liability laws on foreign bribery.

The BCCA brings the country in line with global anti-corruption efforts by:

  1. Permitting corporate liability for violative conduct and
  2. Imposing harsh financial and other types of sanctions

Ellen Zimiles, Joseph Spinelli and Jay Perlman provide expert analysis on the Brazil Clean Company Act and how it impacts businesses.


Investigations Quarterly (IQ) Magazine, Issue 14

This issue of IQ magazine addresses a variety of topics associated with “tone at the top”. Increasingly, senior executives are leading by example and reinforcing organizational integrity as a means to minimizing compliance risks and preserving corporate reputation.



Ellen Zimiles

As the Head of Global Investigations & Compliance practice and leader of the Financial Risk & Compliance segement, Ellen is a leading authority on anti-money laundering, regulatory and corporate compliance, fraud control, and public corruption matters.

Jay Perlman

Jay Perlman is a director with the Global Investigations & Compliance segment, and has 20 years of legal, regulatory compliance and investigative experience in the financial services and corporate sectors.

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