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On February 6, 2018, District Law No. 6,112/2018 was published in the Federal District Official Gazette.

The law determines the mandatory implementation of a compliance program for companies that enter into contract, partnerships, agreements, concessions, or public-private partnerships with the public administration of the Federal District,  in amounts equal to or greater than the bid price, estimated between BRL 80,000 and BRL 650,000. The requirement applies only to contracts with a term equal to or greater than 180 days.

Article 6 sets the parameters by which the compliance programs will be evaluated, these parameters are practically the same as those provided in Federal Decree No. 8,420/2015, with the exception of the last subsection that innovates in determining the promotion of a set of actions in order to promote an ethical and integrity culture in the companies through lectures, seminars, workshops, debates and similar events.

Following the requirement set forth in Ordinance No. 909/2015 of CGU, the law also requires the companies to submit a profile and conformity reports in order to evaluate the effectiveness of their programs.

In the event of non-compliance with the requirements established by the law, a fine of 0.1% per day shall be imposed, based on the updated value of the contract.

The requirements foreseen in the law apply to contracts already in force with a term greater than 12 months, in which case companies will have 180 days to adapt.


Alessandro da Cruz is a senior associate at the Compliance & Investigations practice group of Trench Rossi Watanabe (in cooperation with Baker McKenzie) in São Paulo, Brazil. In the anticorruption compliance field, his practice includes assistance in matters involving the Brazilian anticorruption framework, FCPA and other anticorruption legislation, internal investigations (including multijurisdictional cases), development, revision and implementation of compliance programs, training of employees, risk assessments and due diligence in the context of M&A transactions.