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Progress has been made in Brazil, but questions remain

Shin Jae Kim ( is the head of the Compliance & Investigation practice at TozziniFreire Advogados in São Paulo, Brazil.

Brazil has experienced a significant growth in self-reporting and cooperation in the anticorruption arena over the last few years.

The growth was prompted by the combination of factors, including increased enforcement—mainly involving infamous Operation Car Wash[1] —and the possibility for companies and individuals to settle corruption charges by cooperating with authorities. Prior to Operation Car Wash, cooperation and voluntary disclosure as investigative tools were only possible for companies in the antitrust arena and for criminal cases involving individuals.

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