Matteson Ellis commented on the recent rules implementing a Brazilian anti-bribery law that has been on the books for more than one year. The law was passed in the midst of anti-corruption protests and the firing of several government ministers, and the recent regulations implementing the law were approved under similar circumstances, Ellis said. "It took these country-wide protests to finally pass the legislation. In a way, it's similar now."

Brazilian President Dilma Rousseff's issuance of the rules comes on the heels of a corruption scandal surrounding her administration after recent re-election. "Dilma is under a lot of pressure," Ellis said, who was commenting on the issue from Rio de Janiero, where he saw demonstrators marching before the rules were issued.

The law went into effect in January 2014 and the Organization for Economic Cooperation and Development urged Brazil to issue rules expediently so that It could properly be enforced. The regulations provide more detail on how to determine penalty levels for offenses, the parameters for companies seeking leniency agreements and the elements of an acceptable compliance program, Ellis said.

Ellis's comments were also published in an article titled "March Bribery Digest -- Beyond FCPA Compliance" in JDSupra Business Advisor on April 15, 2015.