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Progress has been made in Brazil, but questions remain, cont'd.

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

In my last column,[1] I wrote about the growth in self-reporting and cooperation with local authorities in the anticorruption arena over the last few years, and how dealing with multiple authorities to negotiate leniency agreements in Brazil could be challenging.

On August 6, 2020, a technical cooperation agreement (TCA) was signed by the Brazilian Office of the Comptroller General (CGU), the General Attorney’s Office (AGU), the Federal Court of Accounts, and the Ministry of Justice and Public Security.[2] The TCA was signed with the Supreme Court’s coordination and set certain principles and premises for the negotiation and signature of leniency agreements, highlighting mutual cooperation and information flow among the authorities. The new standards imposed by the TCA might affect ongoing leniency agreement negotiations and agreements already signed.

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