Compliance investigations have increased exponentially, since compliance programs were consolidated in companies globally.

To reflect on what can make good people do bad things, I will mention two real cases, which occurred during my career.

In May 2020, the Federal Court of Auditors - TCU, in partnership with the international non-governmental organization Transparency International marked a point in favor of tackling corruption and legal certainty for the federal, state and municipal public managers, by launching a booklet called “Recommendations for Transparency of Emergency Contracts in Response to COVID-19“. The booklet guides those professionals, in face of Act 13,979 / 2020, to adopt accurate and licit practices in the management of public resources in the pandemic scenario.

On the afternoon of May 28th, a webinar was held with the topic ‘Health Fraud! How does the US government combat this problem’, led by Alexandre Dalmasso, partner and responsible for the Ethics and Compliance Practice Group.

Currently, according to the UNCTAD - United Nations Conference on Trade and Development, here is the current scenario regarding the regulation of Data Protection and Privacy in the World:

The European Data Protection Board (EDPB) issued on May 4, 2020 the Guide 05/2020 with rules applicable to the consent of the personal data, under the Data Protection Law, in force at the European Union - GDPR (General Data Protection Resolution).

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The gap between the issuance date of a law and the effective date is called vacatio legis. The reason, in general, for a law not to enter into force on the date of its publication is because the legislator wishes to provide society with time enough to become aware and prepared to respect its content.

The compliance officer is briefly the facilitator in consolidating a culture of compliance within the organization, and should be the first to set an example, with respect to behaviors and attitudes when interacting with internal and external clients.

Regardless of whether an employee is hired under an employment contract or just by signing in the employment and social security card, his / her initial duty of loyalty to the company is not challenged, which after all, pays his / her compensation for their services and waits in return for his / her commitment to the development of the corporation's business.

On the afternoon of April 15th, a webinar was held with the topic "Compliance Investigation", led by Alexandre Dalmasso, partner and responsible for the Ethics and Compliance Practice Group. The webinar aims to discuss the best practices and main challenges for successful compliance investigations, unraveling the investigation phases, identifying gaps in the process and how to implement improvements based on the results obtained.

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At the beginning of the millennium, when the so-called 1st compliance wave occurred, a document started to gain evidence: the Code of Conduct.

Some time ago, I came across an unusual situation ... there was a company that allowed its employees to use a taxi as a mean of transportation due to some need related to the company's business. There were no major controls and, oddly enough, a receipt from the taxi was not even required for accountability.

Although several governments are striving to combat and mitigate corruption and its consequences, since talking about eradicating corruption is an almost utopian task, it is important to know the world´s players in this fight.

Corruption Perceptions Index or simply CPI is an index created by a non-governmental organization named Transparency International (www.transparency.org), which, among other purposes, has set out to monitor countries' progress in fighting corruption around the world.

Red flags mean situations that deserve special attention and that must be carefully observed by managers and, mandatorily, by compliance officers and auditors. In short, they are warning signs, which should not and cannot be ignored.