Multinational companies and their executives operating in Brazil have increased cause to tread carefully with respect to anti-corruption compliance. In March, Brazilian authorities filed criminal charges against Chevron Corp. and Transocean Ltd. executives in connection with a relatively minor November 2011 oil spill, and a Brazilian judge barred the executives from leaving the country in order to face the charges.
Brazil’s recent actions to enforce its laws and detain foreign executives, in combination with Brazilian President Dilma Rousseff’s demonstrated anti-corruption efforts, indicate a new regulatory age in Brazil. President Rousseff’s government appears poised to enforce its domestic anti-corruption laws against multinational companies and executives, thus raising the stakes for operating in Brazil. It is therefore imperative for companies operating in Brazil to have contingency plans in place to deal with the changing regulatory winds.