Monday, June 11, 2018

Brazilian Securities Commission will analyze corruption cases in Public Corporations



Last week, the Brazilian website JOTA published an article about the Brazilian Securities Commission – “CVM”´s intensions to investigate corruption cases in public corporations as breach of fiduciary duties. This news may have great impact in current and future cases involving shareholders and corporations. At this moment, Petrobras could be the first target of the Regulatory Agency.

In one hand, the arbitrations currently running between shareholders and Petrobras are not public, in the other hand we might be able to have administrative precedents available from the Brazilian Securities Commission.

Though CVM is not competent to pursue criminal charges against a corporation it is in charge of analyzing such facts in lights of a fiduciary duties perspective. Last week, one of CVM directors stated to the specialized press that the regulator could act in this case if the criminal behavior falls into a violation of fiduciary duty.

In this sense, if the director of a public corporation divert money from the company to benefit other parties illegally and misrepresent those transactions in the financial statements, it is clear that he violated his fiduciary duties to the company and to the shareholders.

In sum, it is important to point out that a CVM decision is administrative in nature, and it does not automatically creates remedies to the shareholders. CVM may punish the directors and managers who violated their duties with fees and other sanctions, but shareholders who are still interested in seeking any recovery for damages against Petrobras and its directors and managers will need to start an arbitration or join one of the existing cases, if this joinder is still possible.


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