Corruption, Compliance, and Corporate Governance in Brazil

In this episode of Brazil (is not) for Beginners, Isaac Matzner sits down with Juliana Wainstein, a lawyer and member of the compliance team at FAS Advogados - part of the CMS group - for a timely conversation about corruption, organized crime, and the growing importance of compliance in Brazil’s business environment.

The backdrop for this conversation is hard to ignore: Banco Master, Carbono Oculto, and the recent designation of the Brazilian criminal gangs as a terrorist organization by the United States, have proven that organized crime in Brazil is no longer just on the streets; it is infiltrating the heart of the financial system. Isaac and Juliana discuss how the sophistication of modern money laundering - where fintechs, logistics networks, and complex corporate structures, are used as fronts for illicit operations - is helping put compliance front and center for companies operating in Brazil.

The conversation moves from the mechanics of how organized crime infiltrates legitimate businesses, to what a real compliance program looks like in practice, and since it’s 2026 to the role AI is playing on both sides of the equation. Juliana also makes a case that many companies miss or chose to overlook: compliance, done right, is not a cost or a constraint, it’s a competitive moat, and one of the best tools a company has for long-term success in Brazil’s complex business environment.

Other key topics include:

• How Carbono Oculto worked - from gas production to fintech pocket accounts - and what it revealed about the convergence of licit and illicit operations
• Why logistics, payments, and financial services are the sectors most exposed to criminal infiltration
• Cash payments as a red flag, and the double-edged nature of Pix in the compliance landscape
• The PCC’s US terrorist designation and what it means practically for Brazilian and American companies doing business together (OFAC, SDGTs, the 50% rule)
• How vulnerable people are recruited into financial crime: fake account openings, stolen credentials, and the debt cycle inside Brazilian prisons
• What a real compliance program looks like - from diagnosis and risk matrix to training, whistleblower channels, and culture change
• Why compliance should start at day zero, regardless of company size
• The ‘broken windows’ logic of compliance culture, and why the little habits matter as much as the big policies
• How BTG and other large institutions are using AI to accelerate KYC - and how deepfakes are being used on the criminal side
• What foreign companies consistently get wrong when bringing compliance programs to Brazil - and how to localize them properly
• And much more…
  

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