Compliance Programs for Brazilian Public Entities: An Additional Positive Imitative to Combat and Prevent Corruption and Bribery in Brazil

The Brazilian Office of the Comptroller General (Controladoria Geral da União – CGU) enacted Directive No. 784/2016, on April 28, 2016, creating the Program to Promote Integrity in Public Service (PROFIP – Programa de Fomento da Integridade Pública) that intends to give guidelines to incentivize entities of the federal public administration to adopt compliance programs. In fact, although the enforcement of anti-corruption violations have increased significantly in Brazil, especially since the “Car Wash” Operation, very little has been discussed for the adoption, by public authorities, of compliance programs (referred to in the Directive as Integrity Programs).