Opinion, by Michael Royster
RIO DE JANEIRO, BRAZIL – January 29th, 2014, one year ago, Brazil’s first Anti-Corruption Law (12.846/13) came into effect, six months after it had been voted by Congress. It had three novel and drastic features: strict liability in civil in administrative cases; fines up to twenty percent of annual turnover; and leniency agreements for collaborating defendants.
Almost all federal laws are regulated, usually within six months, by a Decree, signed by the President. So far, no Decree has been issued. Many are asking the obvious question: "why not?”
Under the statute, the federal . . .