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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 . . .

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