02/09/2026
Director Criminal Liability in Brazil - What every foreign executive in Brazil should know
1 - Personal liability of company directors
In Brazil, an investigation can reach directors and legal representatives directly — including foreign nationals without permanent residence in the country — in cases of fraud, reckless management, or deliberate compliance omissions.
2 - Exposure under the Anti-Corruption Law
Contracts and interactions with the public sector place the company under strict liability under Law 12,846/2013 — regardless of whether fraudulent intent is proven.
3 - LGPD and criminal law reflexes
A data breach isn’t only an administrative matter. When it involves unauthorized access or fraud, it can trigger parallel criminal exposure for the company and those responsible.
None of these risks are eliminated after the problem appears.
Want to understand the specific risk facing your operation in Brazil? Our team is available for a preliminary, confidential assessment.
