HSE University Anti-Corruption Portal
Brazil Adopts a National Anti-Corruption Strategy

Brazil’s Inter-Agency Committee for Combating Corruption (Comitê Interministerial de Combate à Corrupção, CICC*) has released the National Anti-Corruption Strategy 2021 to 2025

The Strategy is designed to systematise and improve the existing mechanisms for preventing and detecting corruption crimes and holding those who commit them liable, as well as to ensure the coordination of efforts of different public bodies performing certain functions in this realm. 

To this end, the Strategy identifies 15 key areas to which the bodies responsible for developing and implementing national anti-corruption policy will pay attention in coming years:

  • public ethics,
  • management and governance,
  • prevention of conflicts of interest,
  • integrity measures,
  • internal control,
  • conduct of investigations,
  • liability of natural and legal persons,
  • financial and budgetary area,
  • anti-money laundering measures,
  • asset return,
  • inter-agency coordination,
  • international cooperation and coordination,
  • scientific research, knowledge building and innovation,
  • institution of ombudsman,
  • transparency and exercise of public control.

The development of the document consisted of two stages:

  1. Analysis of anti-corruption mechanisms, whose employment is coordinated and controlled by the public bodies which are members of the CICC;
  2. Development of a plan of actions to be carried out by the respective authorities between 2021 and 2025.

The analysis included a review of the existing national anti-corruption instruments and the degree of implementation of recommendations of international organisations made to the country in the framework of the review of implementation of the UN Convention against Corruption, the OECD Convention on Combating Bribery of Foreign Public Officials in International Business Transactions and the Inter-American Convention against Corruption. The mapping of potential methods for improving respective activities of each CICC member agency aimed at fighting corruption was also conducted. 

The analysis concluded with the development of an action plan incorporating 142 measures for enhancing the effectiveness of public administration in the prevention of and fight against corruption assigned to competent authorities. 78 of these measures are centered on the prevention of corruption, 34 on its detection and the remaining 30 on the provision of financial control and accountability. 

Comptroller General of the Union 

Most targeted measures are addressed to the Office of the Comptroller General of the Union, a body responsible for assisting the President of Brazil in the matters regarding the protection of public assets and enhanced transparency of public administration through internal control, public audit and prevention of and fight against corruption. They include: 

  • Development of new rules for protecting persons requesting information and guaranteeing their anonymity;
  • Creation of a computerised system for gathering information about politically exposed persons;
  • Formulation of the rules for ensuring transparency of beneficial owners of public resources;
  • Restructuring of the open data portal;
  • Improvement of legislation on the prevention and detection of conflicts of interest in the federal executive bodies and introduction of a digital system for managing conflicts of interest (the relevant legal act has already been adopted);
  • Update of the rules of ethical conduct in federal executive bodies and creation of a computerised system for managing the cases of infringement of ethical norms;
  • Drafting of a bill regulating the private representation of interests (lobbying) at the national level;
  • Implementation of the Project entitled “Corruptibility Index” that provides for the creation of a platform containing statistics on corruptibility of natural and legal persons and officials; 
  • Development and implementation of a Federal Strategy for Social Integrity;
  • Promotion of integrity in the private sector through the encouragement of voluntary adoption of the respective set of corporate measures;
  • Development of a model allowing for accelerating the interaction between anti-corruption bodies and improving the decision-making process during investigations;
  • Improvement of methodology for the analysis of information about mitigation agreements, creation of a portal for managing the information about mitigation agreements, and others.

Ministry of Justice and Public Security

The Ministry of Justice and Public Security is a federal body responsible, in particular, for the development and implementation of state anti-corruption policy, participation in international legal cooperation in this area, including coordination of asset recovery, management of the National Strategy for Combating Corruption and Money Laundering and the National Training and Capacity Building Programme on Combating Corruption and Money Laundering, etc. 

The measures to be taken by the Ministry of Justice and Public Security include:

  • Establishment of a National Network of Judicial Police Divisions for Combating Corruption and provision of training for officers;
  • Development of policy for combating corruption, money laundering and organised crime;
  • Planning and participation in international anti-corruption forums, and others.

Federal Police

The anti-corruption sector of the Federal Police of Brazil consists of the following divisions: the Coordination Centre for the Fight against Corruption and Money Laundering, Service for Data Analysis, Anti-Corruption Desk, Anti-Money Laundering Desk and Service for Combating Financial Crimes. Besides that, there is a police station responsible for combating corruption and financial crimes in each of the 27 regional offices of the Federal Police. 

The measures of the plan targeted at the Federal Police regard investigations and work on ensuring integrity and include, in particular:

  • Development of guidance on conducting investigations concerning the public budget, based on data analysis;
  • Gathering of information and statistics on criminal organisations;
  • Update of all thematic guides distributed by the Anti-Corruption Desk;
  • Raising awareness among young people about integrity by conducting social education events and lectures on moral and ethical norms targeted at this social group across the country, and others.

Ministry of Economy

The Ministry of Economy is the central body for public procurement and it is responsible together with other bodies for the development of rules ensuring its effectiveness and transparency. In addition, the authority is mandated to select and train civil servants on the issues of integrity and effectiveness of their service as well as to promote ethical culture. 

The measures addressed to the Ministry of Economy are the following:

  • Assessment of the beneficial owners of public resources;
  • Creation of an Integrated Register of Investment Projects;
  • Update and Review of the legislation establishing the rules for the assessment of effectiveness of the public sector, and others.

Attorney General of the Union

The Attorney General of the Union is responsible for protecting interests of the State in and out of court and providing legal advice and advice as an executive body. The functions of this body also include the protection of interests of the State in proceedings concerning asset return and anti-corruption. 

The measures addressed to the Attorney General are, in particular, the following: 

  • Update of the rules for regulating the conduct of negotiations on mitigation agreements;
  • Analysis of the effectiveness of legal claims for the recovery of proceeds of corruption, and others.

*The Inter-Agency Committee for Combating Corruption, established by Decree No. 9.755 of 11 April 2019, is aimed at providing the President of Brazil with advice on the development, implementation and assessment of the effectiveness of anti-corruption policy. It is composed of:

  • the Comptroller General of the Union (coordinator of the Committee); 
  • the Ministry of Justice and Public Security; 
  • the Ministry of Economy; 
  • the Institutional Security Cabinet; 
  • the Attorney General of the Union; 
  • the Central Bank of Brazil. 
Conflict of interest
Asset recovery
Civil society
International cooperation
Anti-corruption authorities

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