Lobo de Rizzo

On September 11, 2025, the Office of the Comptroller General (CGU) published Normative Ordinance SE/CGU No. 226, which establishes criteria and procedures for evaluating Compliance Programs, in accordance with Decree No. 12,304/2024. The regulation provides for the assessment of corporate compliance programs in three specific situations: &nbsp;<img class="image_resized" style="width:75%;" alt="Imagem1.png" src="https://d1nwhe1xgpgddb.cloudfront.net/Imagem1_bf3287e034.png" srcset="https://d1nwhe1xgpgddb.cloudfront.net/Imagem1_bf3287e034.png 245w, https://d1nwhe1xgpgddb.cloudfront.net/Imagem1_bf3287e034.png 500w, https://d1nwhe1xgpgddb.cloudfront.net/Imagem1_bf3287e034.png 750w, https://d1nwhe1xgpgddb.cloudfront.net/Imagem1_bf3287e034.png 1000w" sizes="100vw" width="1000">Evaluation parameters include senior management commitment, existence of a code of ethics and compliance policies, risk management mechanisms, reporting channels, disciplinary measures, third-party due diligence, and continuous program monitoring. Factors such as company size, industry sector, and level of interaction with the public administration are also considered.For large-scale public contracts (BRL 251 million or more), the Ordinance establishes that contracts with the Federal Executive Branch must submit documents and information which evidence the implementation of the Compliance Program within thirty (30) days following the end of the six-month period from the contract’s signing.The submission must be made through the Compliance Programs Assessment and Monitoring System (SAMPI), by completing the profile and conformity forms. Companies already certified under the CGU’s Empresa Pró-Ética Program, or currently undergoing evaluation by the CGU, may be exempted from submission.The Ordinance also provides that having implemented an effective Compliance Program can be used as a tie-breaking criterion in public bids. This requirement can be demonstrated through:&nbsp;→ Self-assessment under the Pacto Brasil pela Integridade Empresarial, valid for up to twenty-four (24) months; → Inclusion in the list of companies recognized under the Empresa Pró-Ética Program; or → Assessment conducted in the past twenty-four (24) months by compatible public authorities. Public bodies and entities must explicitly include in bidding notices the possibility of using the Compliance Program as a tie-breaking criterion, in accordance with the Ordinance’s parameters.From a business and legal perspective, the Ordinance has direct implications for companies contracting with the Public Administration, particularly in large-scale contracts. Starting sixty (60) days after its publication, companies involved must ensure proper implementation of their Compliance Programs, not only to comply with legal requirements but also to potentially benefit in bidding processes by using the effectiveness of their programs as a tie-breaking criterion. &nbsp;

CGU defines criteria and weight of Compliance Programs for contracts with the Federal Executive Branch

Brazil has taken another step towards establishing a regulatory framework for offshore wind. Through Ordinance No. 851/2025, the Ministry of Mines and Energy (MME) has launched Public Consultation No. 191/2025 to gather feedback on a proposed methodology for identifying marine areas to be made available for offshore wind development. Prepared by the Energy Research Office (EPE), the proposal outlines technical and regulatory criteria to guide the identification and prioritisation of suitable areas. The initiative seeks to provide predictability to private investors while promoting the orderly, safe, and sustainable use of Brazil’s marine space.<h2>Submission period and procedure for contributions:</h2>Contributions may be submitted through the websites of the MME or Participa + Brasil within 20 days from the ordinance’s publication on 14 July 2025 — that is, until 4 August 2025.The methodology is structured around three key stages: &nbsp;<img src="https://d1nwhe1xgpgddb.cloudfront.net/Imagem3_3f1db1c916.png" alt="Imagem3.png" srcset="https://d1nwhe1xgpgddb.cloudfront.net/thumbnail_Imagem3_3f1db1c916.png 245w,https://d1nwhe1xgpgddb.cloudfront.net/small_Imagem3_3f1db1c916.png 500w,https://d1nwhe1xgpgddb.cloudfront.net/medium_Imagem3_3f1db1c916.png 750w,https://d1nwhe1xgpgddb.cloudfront.net/large_Imagem3_3f1db1c916.png 1000w," sizes="100vw" width="3991" height="1241"> The proposal was developed in dialogue with the Offshore Wind Working Group, which includes representatives from government bodies, regulatory agencies, and the national grid operator (ONS).For stakeholders in the energy sector, this is a timely opportunity to help shape the spatial planning of offshore wind in Brazil.Our Oil &amp; Gas team is available to support the preparation of submissions or clarify any questions regarding the consultation process.

Offshore wind: Brazil opens consultation on marine area selection criteria

We are pleased to announce the expansion of our team of partners with the promotions of Bruno Laurito Pinheiro, from the Infrastructure area; and George de Magalhães Carvalho and Hugo Johan Silverio Wery, both from Corporate, Mergers and Acquisitions.These promotions reflect the firm's commitment to recognizing talents who have had the opportunity to develop their careers within Lobo de Rizzo in recent years and to strengthening our operations, in line with our growth strategy for the coming years.With extensive experience, Bruno Laurito Pinheiro has been working for over 10 years in structuring and implementing infrastructure projects, especially involving concessions and privatizations, in various sectors such as power, basic sanitation, logistics (urban transportation, highways, ports, airports and railways), health, urban furniture, public utility equipment and services, among others.Bruno Laurito Pinheiro works in all stages of structuring and implementing projects, from the conception of the legal model, through the stages of development, financing, bidding, contracting and management, including acting before audit courts and regulatory agencies (ANEEL, ANTAQ, ANP, ANVISA). He holds a degree in Law from Pontifícia Universidade Católica (PUC-SP) and is a member of the Infrastructure Committee of the Chamber of Business Mediation and Arbitration – Brazil (CAMARB).George de Magalhães Carvalho has extensive experience in mergers and acquisitions (M&amp;A), joint ventures structuring, and corporate reorganizations, advising both national and international clients, including publicly traded companies, private equity funds and venture capital funds. His practice spans different economic sectors, with an emphasis on innovation and technology, education and franchising. He also has significant expertise in matters related to stock options, incentive plans and executive remuneration.In the franchising sector, George specializes in strategic consulting, negotiating complex contractual instruments (including franchise and master franchise agreements) and structuring the legal framework for large national and international franchise networks. In the area of innovation and technology, his expertise includes knowledge of intellectual property, copyright and software matters and in the negotiation of complex agreements and strategic transactions where innovation and technology play a central role.George also contributes institutionally, participating in innovation and knowledge management initiatives, contributing to the development and implementation of solutions that support Lobo de Rizzo in offering cutting-edge services to its clients. He graduated in Law from Fundação Getulio Vargas (FGV-SP).Hugo Johan Silverio Wery has experience in mergers and acquisitions, corporate restructuring, joint venture structuring and corporate law consulting.He has solid regulatory knowledge in matters involving FIPs and asset managers and administrators, in addition to leading complex infrastructure projects, advising the government and players in sectors such as sanitation, power and ports. He also advises domestic and foreign clients on issues related to various commercial contracts. He holds a law degree from the Pontifical Catholic University (PUC-Rio).

Lobo de Rizzo promotes partners in Infrastructure and M&A

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Brazilian Central Bank Issues Regulatory Framework on Virtual Asset Service Providers

Lobo de Rizzo establishes multidisciplinary WorkGroup to advise on legal risks associated with US-Brazil bilateral trade

Lobo de Rizzo

CGU defines criteria and weight of Compliance Programs for contracts with the Federal Executive Branch

Offshore wind: Brazil opens consultation on marine area selection criteria

Lobo de Rizzo promotes partners in Infrastructure and M&A

Practice areas

Our team

Responsibility and commitment

Legal technology

Brazilian Central Bank Issues Regulatory Framework on Virtual Asset Service Providers

Lobo de Rizzo establishes multidisciplinary WorkGroup to advise on legal risks associated with US-Brazil bilateral trade

Lobo de Rizzo

CGU defines criteria and weight of Compliance Programs for contracts with the Federal Executive Branch

Offshore wind: Brazil opens consultation on marine area selection criteria

Lobo de Rizzo promotes partners in Infrastructure and M&A

Practice areas

Our team

Responsibility and commitment

Legal technology

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