Those who read Portuguese may check here a brief comment I have posted at Jus Navigandi on a recent case law of the Board of Appeals of the National Financial System. This Board operates as an administrative court hearing appeals against certain orders passed by the Central Bank, by the Superintendence of Private Insurance and by the Securities and Exchange Commission of Brazil. It found that a penalty imposed on Intra S.A, subsequently merged into Citigroup Global Markets Brasil, could not be enforced. Importantly so, the 2013 anti-bribery law was taken into account in deciding to what extent a surviving company could be liable for administrative liabilities of the acquired company.
Recurso 13230 – Conselho de Recursos do Sistema Financeiro Nacional – Board Rapporteur: Marcos Martins Davidovich. Dissenting opinion: Bruno Meyerhof Salama. Publicado em 20.02.2015. In Portuguese here.