Matteson Ellis was quoted regarding enforcement policies of Brazil's Clean Company Act. The Brazilian anti-bribery law differs from its U.S. and U.K. counterparts because enforcement is decentralized and authorizes enforcement by the highest authority affected by the alleged fraudulent conduct. "There are a very large number of entities enforcing the law. This is making companies quite scared," Ellis said. "What is a multinational company to do if they’re operating all over the country? Are they subject to risk at all levels of government? Under the language of the statute, they are."