In recent years, the anticorruption regimes in both Brazil and Canada have undergone significant reform, following the international trend in cracking down on corruption started by the U.S. in 1977.

Both Brazil and Canada are signatories to the Organização para a Cooperação e Desenvolvimento Econômico/Organization for Economic Cooperation and Development’s 1997 Convention on Combatting Bribery of Foreign Public Officials in International Business Transactions (the “OECD Convention”). The OECD Convention requires parties to implement laws prohibiting the bribing of foreign officials and impose effective penalties for violating those laws.

The fight against corruption, particularly in the public sector, has been on Brazil’s agenda for a while. On January 29, 2014, Law No. 12.846 came into force in Brazil, which, for the first time, imposes civil liability on domestic and foreign companies and other legal entities in Brazil for certain corrupt acts. Brazil is now in compliance with the recommendations of the OECD.

Canada has also stepped up its anticorruption efforts as of late. On February 14, 1999, Canada’s Corruption of Foreign Public Officials Act (“CFPOA”) came into force, bringing it into compliance with the OECD Convention. In June 2013, Canada strengthened its anticorruption efforts by passing Bill S-14, the Fighting Corruption Act, in response to recommendations made by the OECD’s Working Group on Bribery.

The following compares and contrasts the anticorruption regimes in Brazil and Canada, and suggests potential avenues for further reform.