Acting Brazil President Dissolves Anti-Corruption Agency
Friday, May 13, 2016 at 11:28AM
Luiz Phillip Guarani Moreira and Andy Spalding in Brazil, Clean Company Act, Dilma Rousseff, Michel Temer

The first formal act of Brazil’s interim president has been a Provisional Measure that completely dissolves Brazil’s main anti-corruption enforcement agency, the Comptroller General (CGU).

Michel Temer, pictured left, who assumed office yesterday following Dilma Rousseff’s removal to stand trial for impeachment, approved the Provisional Measure No. 726 of May 12, 2016, which was published today in the Brazilian Official Gazette.

This Provisional Measure dissolved and/or merged a series of Ministries of the Brazilian Federal Executive Power, changing the entire structure of the Federal Government.

The CGU authored Brazil’s watershed 2014 anti-corruption law, the Clean Company Act, and was charged with principal enforcement authority over corporations.

Temer has replaced the CGU with a new Ministry of Transparency, Monitoring and Control. His motives for doing so remain unclear, as do the composition and powers of the new Ministry. It appears to be an effort to streamline federal agencies, cutting costs in a time of recession and spiraling deficits.

The measure may change the CGU in name only while preserving important enforcement authority.  But it may not. The impact on anti-corruption enforcement remains unclear.

We are of course following the story closely and will post updates on the FCPA Blog.


Luiz Phillip Guarani Moreira is an Associate Attorney in the Compliance and Anti-corruption practice of Souza, Cescon, Barrieu & Flesch Advogados in São Paulo, Brazil.

Andy Spalding is a Senior Editor of the FCPA Blog and Associate Professor at the University of Richmond School of Law. He'll be a moderator and panelist at the FCPA Blog NYC Conference 2016.

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