Compliance in Brazil for foreign companies: the essentials

Summary

A foreign subsidiary's Brazilian compliance baseline rests on four pillars: the Anti-Corruption Act, the LGPD, international sanctions and counterparty due diligence. A defensible minimum includes written policies, documented training, a reporting channel and annual review.

Brazilian Anti-Corruption Act

Legal entities face strict liability for misconduct involving Brazilian or foreign public authorities. An effective integrity program may reduce penalties and is required in several public procurement processes.

LGPD and personal data in Brazil

Any operation processing personal data of people in Brazil, including customers, suppliers and applicants, may be subject to the LGPD regardless of where the company is headquartered. The operation needs a legal basis, a data protection officer and an accessible channel for data subjects.

Frequently asked questions

Can a Brazilian subsidiary reuse the group's global compliance program?

Partly. The general framework may be reused, but policies, training and reporting channels need a Portuguese version and adjustments for Brazilian law.