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Brazil’s Clean Company Act: How U.S., U.K., and Global Models May Influence Enforcement

Brazil’s new anti-bribery law (Law no. 12.846/2013), often referred to as the “Clean Company Act,” officially took effect on January 29, 2014. This article compares key elements of the Clean Company Act with the U.S. Foreign Corrupt Practices Act (“FCPA”) and the U.K. Bribery Act 2010 (“Bribery Act”) and considers the outlook for enforcement of the bribery offenses in the new law in the context of U.S., U.K., and global trends.

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