The opening months of 2026 have produced a series of enforcement actions that signal the continued maturation of Brazil’s anti-corruption framework. The Office of the Comptroller General (“CGU”) and the Office of the Attorney General (“AGU”) signed two new leniency agreements with companies operating in the animal protein sector, while the São Paulo State Comptroller General (“CGE-SP”) imposed on Fast Shop S.A. (“Fast Shop”) the largest administrative fine ever recorded in Brazil under Federal Law No. 12,846/2013 (“Clean Companies Act” or “CCA”).

The companies involved cooperated with the investigations by providing information and documentation, which enabled the advancement of proceedings against the public officials involved. In addition, their integrity programs were assessed by the Brazilian authorities, serving as a central variable in both the negotiation of the leniency agreements and the calculation of administrative fines.

Bonasa

The leniency agreement signed by Bonasa Alimentos Ltda. (“Bonasa”) concerned the payment of undue advantages to agricultural inspectors affiliated with the Ministry of Agriculture and Livestock (“MAPA”) in the State of Tocantins, in connection with two major federal police investigations, the Lucas and Vegas Operations. The unlawful acts were committed between 2013 and 2017 to obtain favorable treatment in sanitary inspection activities.

Bonasa voluntarily approached the CGU and the AGU to present a cooperation proposal, initiating negotiations that continued through 2025. Throughout the negotiation process, Bonasa provided documents, information, and evidentiary materials that contributed to the clarification of the facts under investigation and to the accountability of the other individuals involved.

In addition to paying a fine of BRL 631,799.744, Bonasa committed to enhancing its integrity program. These measures included reinforcing senior management’s commitment to compliance, formalizing the responsibilities of the compliance function, and conducting periodic training sessions for employees and third parties.

JBJ and Prima Foods

Also in January 2026, the CGU and the AGU entered into a leniency agreement with JBJ Agropecuária Ltda. (“JBJ”) and Prima Foods S.A. (“Prima Foods”) concerning unlawful acts involving the payment of undue advantages to agricultural inspectors affiliated with MAPA in the State of Goiás. The cases are linked to Operetion Conduta de Risco II, which investigated acts committed between 2012 and 2019 to facilitate or conceal sanitary and administrative irregularities.

The agreement was executed jointly with both companies given the common factual background of the investigated violations and the corporate relationship between them: Prima Foods is part of and controlled by the JBJ economic group, which benefited from and was directly involved in the relevant unlawful conduct. The total amount of the agreement was set at approximately BRL 31.1 million, of which approximately BRL 648,000 was attributed to JBJ and approximately BRL 30.5 million to Prima Foods.

As in Bonasa’s case, strengthening the companies’ integrity programs played a central role. Because both companies were found to maintain only formal compliance structures, the agreement established a comprehensive set of measures to strengthen their compliance programs.

Fast Shop

The Fast Shop case presents a markedly different enforcement dynamic. As a result of Operation Ícaro, which investigated an alleged tax corruption scheme involving tax auditors of the São Paulo State Tax Authority (“Sefaz-SP”) and private companies, the São Paulo State Public Prosecutor’s Office (“MPSP”) entered into Non-Prosecution Agreements (“NPAs”) with two shareholders and one statutory officer of Fast Shop, who undertook to pay BRL 100 million as a criminal monetary contribution and to implement measures to strengthen the company’s integrity and compliance program.

In parallel, the CGE-SP initiated an Administrative Liability Proceeding (“PAR”) pursuant to the CCA to investigate the matter. At the conclusion of the proceeding, Fast Shop was fined approximately BRL 1.04 billion, the largest administrative sanction publicly reported under the CCA.

According to the CGE-SP, Fast Shop engaged in unlawful acts consisting of offering undue advantages to a public official, obtaining improper tax benefits, and interfering with inspection and investigative activities. The penalty was calculated to be equivalent to the unlawful benefit identified during the investigation.

In addition to imposing a substantial monetary penalty, the case resulted in requirements to enhance compliance mechanisms and strengthen internal controls.

Conclusion

The three cases examined above are not isolated enforcement episodes but reflect identifiable trends in how Brazilian authorities are approaching corporate anti-corruption enforcement in 2026.

First, state-level enforcement has emerged as a meaningful and independent source of corporate exposure. The Fast Shop case demonstrates that companies face regulatory risk not only from federal authorities but also from state-level enforcement bodies.

Second, integrity programs function as a substantive factor in enforcement outcomes rather than a formal requirement. In both leniency agreements, the CGU and AGU dedicated significant negotiating attention to the quality and effectiveness of the companies’ compliance mechanisms, and the benefits obtained were directly linked to that assessment. The enforcement landscape emerging from these cases sends a clear signal to companies operating in Brazil: the effectiveness of an integrity program, assessed in practice rather than on paper, has become a central determinant of corporate exposure under the CCA.

Independent assessments, internal investigations, and periodic enhancement processes are no longer optional features of a mature compliance program; they are the means by which companies demonstrate to enforcement authorities a genuine commitment to a culture of ethics and integrity and, where misconduct has already occurred, the foundation on which a credible cooperation strategy must be built. 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.