In this Compliance and Investigations newsletter, you will find:
- COAF imposes R$ 7.4 million fine on automotive company for violations of the Anti-Money Laundering Law
- How companies can prepare for the consequences of the PCC and CV being designated FTOs by the US government
- 2026 Corruption Perception Indicators in the Healthcare Sector
1. COAF imposes R$ 7.4 million fine on automotive company for violations of the Anti-Money Laundering Law
In August 2026, Brazil’s Financial Activities Control Council (COAF) imposed a R$ 7.4 million fine on a company in the automotive sector for failing to comply with obligations under the Anti-Money Laundering Law (Law No. 9,613/1998). The violations involved outdated customer records, inadequate transaction records, and a failure to implement policies, procedures and internal controls appropriate to the company’s operations. The sanction is part of a broader enforcement effort by COAF: by June 2026 alone, the agency had already imposed fines exceeding R$ 26 million on companies in the automotive and luxury goods sectors.
The legislation requires all individuals and legal entities that sell luxury or high-value goods, such as automobiles, boats, jewelry and precious stones, to report to COAF any cash transaction of R$ 30,000 or more, as well as transactions that show atypical or unusual characteristics relative to the segment’s standard. It is worth noting that this obligation does not require the reporting party to identify or prove the existence of criminal activity: it is enough to detect indications that could constitute money laundering or terrorist financing (ML/TF) and promptly report them to the agency.
With respect to customer records, obligated parties must keep records up to date and verify whether the customer qualifies as a Politically Exposed Person (PEP), pursuant to COAF Resolution No. 40/2021. When the customer is a legal entity, the procedure must include identification of the ultimate beneficial owner, that is, the individual who ultimately controls the company or exercises decisive power over it.
Finally, in addition to registration, record-keeping and reporting obligations, the law requires parties subject to it to adopt policies, procedures and internal controls proportional to their size and volume of activity, so as to ensure consistent compliance with all of these duties. The case underscores the need for robust, up-to-date compliance structures capable of identifying vulnerabilities, ensuring a prompt response to regulatory requirements, and mitigating legal and reputational risks. To access the media coverage, click here.
2. How companies can prepare for the consequences of the PCC and CV being designated FTOs by the US government
ICC Brazil published a guidance document to help companies across different sectors, whether regulated or not, identify risks and strengthen prevention mechanisms in light of a significant regulatory change: the designation of Comando Vermelho (CV) and Primeiro Comando da Capital (PCC) as Specially Designated Global Terrorists (SDGT) and as Foreign Terrorist Organizations (FTO) by the United States government, a measure that took effect in June 2026.
The complexity of the issue stems largely from how these organizations operate. The PCC and the CV have expanded their activities through lawful and seemingly regular business structures, which makes detection more difficult and requires companies to adopt a more sophisticated prevention posture. To address this challenge, the ICC Brazil document offers practical recommendations for a documented, risk-based strengthening of compliance mechanisms.
Expansion of Corporate Exposure
The main practical consequence of the designation is a change in the nature of corporate exposure. What previously constituted predominantly reputational risk or anti-money laundering and counter-terrorist financing (AML/CTF) risk now also constitutes criminal risk under US extraterritorial legislation. According to the document, companies are subject to this jurisdiction whenever any connecting element is present: transactions in US dollars, use of the US financial system or capital markets, or the involvement of US persons in the transaction.
Documented and Risk-Proportionate Response
Given this scenario, ICC Brazil recommends that companies adopt a documented response calibrated to their risk profile. The goal is not to demonstrate absolute control over every layer of the business, but to show that risks have been identified, assessed and addressed in a timely and proportionate manner.
Among the priority measures highlighted in the document are:
- Documented due diligence proportional to the counterparty’s risk profile, including identification of ultimate beneficial owners, analysis of corporate structure and reputational checks, as well as assessment of red flags;
- Recording of the measures adopted, together with the rationale underlying each decision;
- Implementation of adequate controls and a whistleblowing channel with effective protection against retaliation.
The materialization of these risks was evidenced by a recent measure from the Office of Foreign Assets Control (OFAC), which blocked the assets of two Brazilian citizens and three Brazilian companies identified as PCC operators with transnational reach, including connections in Florida and São Paulo. The case shows that the extraterritorial application of US legislation is already producing concrete effects on Brazilian individuals and legal entities, and reinforces the need to review and improve compliance mechanisms.
Against this backdrop, anti-money laundering and counter-terrorist financing practices, traditionally more developed among financial institutions and companies that sell luxury or high-value goods, are becoming relevant for organizations across all sectors. The controls adopted by these activities can therefore serve as a reference for strengthening other companies’ internal prevention, detection and response structures. To access the full document, click here.
3. 2026 Corruption Perception Indicators in the Healthcare Sector
FGVethics / Instituto Ética Saúde
The study 2026 Corruption Perception Indicators in the Healthcare Sector, conducted by FGVethics in partnership with Instituto Ética Saúde (IES), revealed a high and widespread perception of corruption in the sector. In a multi-sector sample bringing together participants from the public and private sectors, industry and healthcare professionals, 66.8% of respondents rated the level of corruption as high and 21.5% as moderate.
This distrust extends to both public healthcare institutions, such as hospitals, clinics and the Unified Health System (SUS), and private institutions, including hospitals, laboratories, health social organizations, the pharmaceutical industry, health product companies and health plan operators. The consistency of this perception across all regions of Brazil reinforces the understanding that the phenomenon is viewed as structural.
The main vulnerabilities identified involve conflicts of interest, low transparency in procurement processes and public tenders, weak oversight and internal control mechanisms, as well as the normalization of unethical practices and fear of retaliation in whistleblowing cases.
The qualitative stage of the research sought to gain an in-depth understanding of perceptions of corruption, integrity and vulnerabilities in the healthcare sector through structured interviews with representatives from academia and relevant stakeholders in the public and private sectors. The testimonies converge on characterizing corruption as a structural phenomenon, sustained by information asymmetries, conflicts of interest, distorted economic incentives and high opacity in the relationships among professionals, service providers, industry, health plan operators and the public sector.
In terms of mitigation measures, the most frequently cited were the implementation or enhancement of monitoring and control systems and improvements to transparency and accountability mechanisms. The results reveal broad consensus on the need to strengthen governance, accountability and permanent institutional oversight tools in the sector. To access the full study, click here.
