Internacionalização do COMPLIANCE: dos regimes internacionais ao marco jurídico brasileiro

Abstract

This monograph analyzes the internationalization of compliance by examining how foreign rules, multilateral anti-corruption instruments, and international monitoring mechanisms influenced the consolidation of the Brazilian corporate integrity framework. The study is grounded on the hypothesis that compliance in Brazil is not merely the result of an internal development of business law, but rather of a broader process of regulatory convergence between international regimes and domestic institutions. Methodologically, this is a bibliographical, exploratory, and qualitative study, supported by a documentary case study of an illustrative-analytical nature on Odebrecht, based on legislation, institutional guidance, scholarly articles, and official documents. The analysis covers the Foreign Corrupt Practices Act, the Sarbanes-Oxley Act, the OECD Anti-Bribery Convention, the UK Bribery Act, Law No. 12,846/2013, and Decree No. 11,129/2022. In addition to the normative discussion, the research mobilizes the Odebrecht case to demonstrate, from an empirical perspective, the articulation between international cooperation, negotiated settlements, and the restructuring of integrity programs. The findings indicate that compliance has moved beyond the status of a best practice and has become a legally relevant factor for corporate liability, sanctioning, governance, and reputation, whose effectiveness depends on the integration of leadership, risk management, internal controls, third-party due diligence, reporting channels, and continuous monitoring