Federal Agencies will have until March to create anticorruption programs

January 11, 2019

Federal Agencies will have until March to create anticorruption programs

Almost 100 federal agencies will have to prepare their respective integrity plans in the next three months. The measure was published by the Comptroller General of the Union – CGU, as Resolution # n. 57/2019, amending Resolution # n. 1.089/2018, which established the Federal government’s Integrity programs.

The goal of the new Resolution is to “reinforce the anti-corruption agenda, reaching a new structure of the Federal Public Administration” – creation and fusion of the ministries and other organizations/entities.

In April 2018, the regulation of the CGU defined guidelines, steps and deadlines for the creation of integrity programs in 195 entities of the Federal government. The programs should include mechanisms to prevent, detect, remedy and punish fraud and acts of corruption, which should be adapted to the operational risks of each institution. “As such, organizations that have more communication channels with the private sector, for example, need to develop stronger measures”, the CGU says.

The objective is to assist in the setting of effective plans, specific to the reality of each organization/entity, in order to operate a cultural change in the public sector.

The new regulation, like the previous one, establishes three phases and mandatory procedures that enable structuring, execution and monitoring. Beyond bringing new deadlines for implementation, it also updates the concepts of risks and integrity programs. The total number of organizations comprised can still be modified due to the administrative reform’s recent changes.


The first phase, which determines the establishment of specific units for the management of integrity, was initially implemented by almost 130 federal organizations (67% of 195). The remaining institutions will have fifteen days (until January 21st) to designate the area in charge.

In the second phase, the organizations/entities will have to approve the integrity plans, which include characteristics about institutions, data gathering concerning risks and treatment measures, beyond monitoring means and frequent updates. The initial deadline (i.e. November 30th 2018) was met by 91 organizations (47%). The other organizations will have until March 29th to approve their final plans. It is in this second phase that organizations/entities also need to establish or strengthen units like ethics commissions, ombudsmen and inspectors, respectively responsible for receiving and addressing denunciations, promoting rules of conduct; and implementing accountability procedures. According to the CGU, “it is necessary to designate priority areas in charge of dealing with conflicts of interest and nepotism; promoting transparency and access to information; and functioning of internal control”.

The third and last phase defines the means to monitor federal organizations/entities’ entire integrity programs, based on the measures defined in each plan. The institutions should aim at expanding the scope of the integrity program to public policies that they implement or monitor, and to the suppliers and other public and private organizations with which they have contact.

The CGU informed that it will monitor the progression of the phases and conceded deadlines to federal organizations and entities “also giving guidance”.

Official information published by the CGU translated by Licks Attorneys, available online.

More Info

Get in touch with our Compliance group, led by Alexandre Dalmasso, partner at Licks Attorneys: compliancewg@lickslegal.com.