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In a recent decision, the Superintendence of Companies determined that an Excel-based risk matrix of the Self-Control and Integral Management System of Money Laundering, Terrorism Financing and Financing of the Proliferation of matrixes and of the Business Transparency and Ethics Program was insufficient because it did not allow to individualize, measure, assess and mitigate the risks identified.

On 23 April 2024, the Federal Senate approved Bill 6,007/2023, which originated as Bill 200/2015, and which generated intense debate among all those involved in the clinical research ecosystem. While the bill was supported by the economic sectors and part of academia due to the stability and security it brings to clinical research in Brazil, various social segments, part of academia and government authorities who are members of the system raised concerns about the possibility of weakening national ethical guidelines and dismantling the CEP/CONEP system.

The Colombian Tax Office (“DIAN”) and the Superintendence of Companies have entered into an inter-administrative agreement for the exchange of information related to the Ultimate Beneficial Owner Registry, to strengthen the inspection and control functions of these entities and their investigative powers.

On 26 April 2024, the Brazilian Data Protection Authority (ANPD) published the Resolution CD/ANPD no. 15 which approved the Regulation on Notification of Security Incident (“Regulation”). Such Regulation sets forth the mandatory procedures that data controllers must follow when notifying security incidents to ANPD and personal data subjects.
According to Law No. 13,709/18 (Brazilian General Data Protection Law, or LGPD), the controller must notify the occurrence of a security incident that may give rise to relevant risk or damage to data subjects not only to ANPD, but also to the data subjects.

The Superintendence of Industry and Commerce through Resolution No. 17526 of 2024 established the new fees for merger control procedures applicable during 2024. The parties must pay the applicable fee depending on the type of procedure: fast track notification, pre-assessment request phase I or pre-assessment request phase II. These new fees will be effective as of the date of publication of the resolution and the amount must be paid prior to the filing of the application before the SIC.

On 21 March 2024, the National Government issued the Decree 390 of 2024, by which it established the procedure for granting the Leniency Program in transnational bribery and corruption (“Leniency Program”) matters. Under the Leniency Program, it is possible to obtain full or partial immunity from possible sanctions for corruption and transnational bribery. In order to obtain the benefits of the Leniency Program, the company must provide relevant information on the aspects of the commission of such acts and the benefits obtained.

By means of Resolution No. 12/2024, published in the Official Gazette on 24 April 2024 (“Resolution”), the Secretariat of Industry and Commerce amended the regime of advertising of goods and services involving an offer to an undetermined audience; it also repealed Resolution No. 915/2017. The Resolution’s main purpose is to modify the regulations governing advertisements so that they are clearer, more understandable, and useful for consumers. The aim is to simplify the current regime and prevent consumers from being “over-informed,” which could make it difficult for them to make appropriate purchasing decisions.