During the period from July to October 2026, the activity of the Office of the Comptroller General (“CGU”) demonstrated the continued enforcement of Law No. 12,846/2013 (the “Anticorruption Law”). Although the electoral blackout period, in effect since July 4, has reduced the agency’s institutional communications until the end of the electoral period, its anti-corruption agenda has remained active. During this period, CGU and the Office of the Attorney General (“AGU”) entered into two new leniency agreements and CGU also imposed significant sanctions in Administrative Liability Proceedings (“PAR”), took part in dozens of joint operations with the Federal Police (“PF”), and executed commitment agreements with Brazilian companies.

Taken together, these initiatives reinforce the importance of compliance programs in administrative enforcement, both as an element to be taken into account within the scope of the negotiation, or as a relevant factor in determining the consequences applicable to the companies.

The leniency agreement with ARLA Foods

On July 23, 2026, CGU and AGU entered into a leniency agreement with ARLA Foods Ingredientes Comércio de Produtos Alimentícios Ltda. (“ARLA Foods”), a company headquartered in Campinas, São Paulo, engaged in the trade of dairy protein. The agreement, in the amount of BRL 31,056.36, covers conduct that occurred until 2022 in the context of Operation Spy, which investigated the sale of data extracted from internal systems of the Federal Revenue Service.

During the negotiations, CGU examined the company’s compliance program, including its Code of Ethics and Conduct, compliance policies, and internal controls. ARLA Foods ultimately committed to enhancing its compliance program and to continuing to cooperate with the investigations. The case shows that the assessment of compliance programs is not limited to agreements involving substantial sums and is an integral part of the negotiation methodology itself, regardless of the financial magnitude of the underlying conduct.

The leniency agreement with Koenig & Bauer Banknote Solutions S.A.

On October 19, 2026, the CGU and the AGU entered into a leniency agreement with Koenig & Bauer Banknote Solutions S.A. (“KBBS”). The company is headquartered in Switzerland and is part of the German Koenig & Bauer group, operating in the security printing industry. The agreement, in the amount of BRL 69,218,854.26, will be allocated in full to the affected state-owned company, Casa da Moeda do Brasil (the Brazilian Mint). It concludes proceedings ongoing since 2019, which investigated whether contracts with Casa da Moeda had been obtained through acts of corruption between 2008 and 2011.

The same facts had previously been investigated in Switzerland. That proceeding was initiated by the company’s own voluntary self-disclosure and was concluded by the Office of the Attorney General of Switzerland in 2017, with a symbolic fine of CHF 1.00 (equivalent to BRL 6.43) and the disgorgement of CHF 30 million (equivalent to BRL 193,029,000.00) in illicit profits.

As in the ARLA Foods case, during the negotiations the CGU assessed the company’s integrity program, including its Code of Ethics and Conduct, its compliance policies, and its internal procedures and controls. As a result, in addition to making a payment to the Brazilian Mint (Casa da Moeda do Brasil), KBBS has committed to enhancing its compliance program. Furthermore, the company has pledged to provide information in its possession regarding the illicit acts and to continue cooperating with related investigations, thereby reinforcing its commitment to compliance and corporate governance.

The case also highlights the growing coordination among jurisdictions in combating transnational corruption. The self-disclosure made abroad preceded the negotiated resolution in Brazil, which underscores the need for companies with international operations to assess their exposure before different competent authorities in a coordinated manner.

Sanctions imposed in PAR

On the enforcement side, one of the most significant cases involved Qualiprev – Supervisão e Assessoria Ltda. (“Qualiprev”). Through Decision No. 259/2026, published in the Official Gazette on August 12, 2026, CGU adopted the final report of the proceeding committee, imposing on the company a fine of BRL 14,807,970.33, extraordinary publication of the decision, and a declaration of unfitness to bid for or contract with the Public Administration (debarment). The decision was based on Article 5, II, of the Anticorruption Law, which penalizes anyone who finances or otherwise subsidizes unlawful acts provided for in the Anticorruption Law, and on Article 88, II and III, of Law No. 8,666/1993, the former Public Bidding and Administrative Contracts Law – repealed by Law No. 14.133/2021 but still applicable to existing contracts or acts performed while it was in force – which penalizes those who commit illicit acts aimed at frustrating the objectives of the bidding process or who demonstrate a lack of suitability to contract with the Public Administration.

On the same date, through Decision No. 251/2026, CGU sanctioned Oscar Iskin e Cia. Ltda. (“Oscar Iskin”). The penalties were a fine of BRL 22,346,829.95, extraordinary publication of the decision, and a five-year ban on bidding for and contracting with the Federal Government. According to the investigation, the company led a cartel in reverse auctions held by the National Institute of Traumatology and Orthopedics and paid undue advantages to public officials in Rio de Janeiro. The sanctions were based on Article 5, I, III, and IV, “a”, of the Anticorruption Law and on Article 7 of Law No. 10,520/2002 (the Reverse Auction Law). CGU noted that the company neither demonstrated having a compliance program nor adopted any cooperation or remediation measures, which precluded all mitigating factors provided for in Decree No. 11,129/2022.

Commitment agreements

During this period, CGU also executed commitment agreements under CGU Normative Ordinance No. 155/2024. This instrument allows a PAR to be resolved through negotiation, subject to conditions that include the company’s admission of liability and its compliance with the obligations undertaken before the Public Administration.

On July 2, 2026, CGU executed a commitment agreement with IRB-Brasil Resseguros S.A. (“IRB”), providing for a fine of BRL 6,317,473.41. The agreement also requires the company to apply and monitor its compliance program, keeping it aligned with any changes in its risk profile, as well as to respond to requests for information regarding the facts of the proceedings of which it is aware, among other obligations.

Another relevant case took place on August 20, 2026, when CGU executed a commitment agreement with Natulab Laboratório S.A. (“Natulab”), involving reparation in the amount of BRL 722,057.19 and fines totaling approximately BRL 3.16 million. Part of this amount is attributed to Naturelife Indústria e Comércio de Alimentos Ltda., a company subsequently merged into Natulab, for which it is jointly liable for the corresponding obligations. The agreement also requires the compromising party to apply and monitor its compliance program, among other obligations.

Finally, on September 29, 2026, the CGU entered into a commitment agreement with Branco Peres Agro S.A. (“Branco Peres”), providing for a fine of BRL 173,530.95. In addition to paying the fine, Branco Peres undertook to cease its involvement in the wrongful act, to implement and monitor its integrity program, and to respond to requests for information regarding the facts under investigation, among other obligations.

Conclusion

The period shows that CGU is reinforcing the understanding of the integrity program as a continuous and verifiable commitment, rather than an attribute merely declared by the company. This approach is present in all the instruments analyzed. In this context, the effectiveness of compliance mechanisms has gained practical relevance both in negotiations with the Public Administration and in determining the consequences of a finding of liability. Companies must therefore show that these mechanisms are actually implemented, monitored, and adjusted to the risks of their business, rather than merely maintaining formal policies. Saud Advogados regularly advises companies on the design, assessment, and enhancement of integrity programs, as well as on enforcement actions, cooperation, and leniency strategies in Brazil. For more information, please contact our team.