In December, the Brazilian Office of the Comptroller General (“CGU") and the Brazilian Office of the Attorney General (“AGU”) published Normative Instruction No. 36/2022 (“IN 36/2022”), which determines the criteria to reduce up to two-thirds of the amount of the applicable fine in the negotiation of leniency agreements, as provided by Law No. 12,846/2013 ("Anti-Corruption Law").

The main purpose of IN 36/2022 is to increase the predictability of the application of sanctions in the scope of leniency agreements celebrated between investigated legal entities, CGU, and AGU with respect to the practice of unlawful acts against national or foreign public administrations.