Catalogue
Managing Corporate Leniency & Internal Compliance in Brazil

Managing Corporate Leniency & Internal Compliance in Brazil

Designed for managers and compliance teams operating in Brazil, this course provides a comprehensive examination of corporate leniency agreements, internal compliance programme design, and obligations under the Clean Company Act (Law 12.846) and the Anti-Crime Law's bounty system.

This course forms the second part of a two-course set tailored for organisations operating within Brazil's regulatory environment. Building on foundational whistleblowing awareness, this programme equips managers and compliance professionals with the practical and legal knowledge required to navigate Brazil's sophisticated corporate integrity framework, including the negotiation of leniency agreements, the management of internal investigations, and the design of robust compliance programmes that satisfy regulatory expectations.

Participants will develop a thorough understanding of the Clean Company Act (Lei 12.846/2013) and its administrative and civil liability provisions for legal entities involved in corrupt acts against domestic and foreign public administration. The course also addresses the Anti-Crime Law (Lei 13.964/2019), which introduced Brazil's formal bounty system (acordo de não persecução penal and related instruments), expanding the incentives and protections available to individuals who cooperate with authorities in the exposure of wrongdoing.

Through structured lessons covering regulatory bodies, internal reporting mechanisms, leniency negotiation strategy, and the intersection of individual and corporate cooperation regimes, this course prepares compliance teams to lead their organisations toward sustainable ethical conduct and meaningful regulatory engagement. All content reflects the legal framework as established by Brazilian federal legislation and enforced by the Controladoria-Geral da União (CGU), the Ministério Público Federal (MPF), and sector-specific regulators.

Course content

1. The Brazilian Compliance & Anti-Corruption Legal Framework

  • The Clean Company Act: Scope, Liability and Key Obligations
  • The Anti-Crime Law (Law 13.964/2019) and the Brazilian Bounty System

2. Corporate Leniency Agreements: Strategy and Process

  • Understanding the Leniency Agreement Framework
  • Negotiating and Implementing a Leniency Agreement

3. Designing an Effective Internal Compliance Programme

  • The CGU Integrity Programme Framework
  • Internal Reporting Channels and Investigation Procedures

4. Third-Party Risk, Due Diligence and High-Risk Scenarios

  • Managing Third-Party Corruption Risk

5. Regulatory Engagement, Enforcement and Lessons from Practice

  • Key Brazilian Regulators and Enforcement Dynamics
  • Building a Culture of Integrity: Manager Responsibilities

6. Whistleblower Protections and Responding to External Reports

  • Whistleblower Protections in the Brazilian Legal Context

7. Final Assessment

  • Final Assessment
$139.00+ GST, per person
  • 11 lessons
  • Pass mark: 80%
  • Completion certificate

You'll need a learner account to enrol.

Pay for 2–500 seats in one purchase. You'll receive an access code to share with your team.

Total: $695.00 + GST

Completion requirements

  • Lessons and modules must be completed in order — each unlocks when the previous one is finished.
  • Quizzes must be passed (pass mark 80%).
  • Your certificate is issued automatically when every lesson is complete.

Unlock this course for free with a code from your organisation.