Matteson Ellis commented on the prospective success of Brazil's new anti-bribery law. The law "is already having a profound impact, even before one company has been prosecuted," Ellis said, adding "Its adoption has fueled an important shift in Brazil towards corporate compliance, a shift that was already underway given the anti-corruption standards that Brazilian subsidiaries of multinational companies have been introducing for some years now." There are more professionals specializing in compliance as well as an increased number of local companies that are creating formal internal compliance structures, which can cause a shifting paradigm. "Are there still compliance challenges? Yes. Is Brazil still a risky market? Certainly. But the more people who embrace anti-corruption compliance, the easier it is for companies to do business while managing bribery risk," Ellis said.

Regardless of a limited budget supporting the Federal Comptroller General's authority to investigate and apply administrative sanctions, Ellis believes that Brazil is serious about enforcing the new law. "The fact that prosecutors in the country have already shown a readiness and willingness to investigate related misconduct suggests that they plan to take the new law seriously," he said, and added that the "ramp up of enforcement might take time, but indications are that it is moving forward, not backward." Overall, enforcement is the key to the law's success. "To realize the benefits of these types of laws, Brazil must also dedicate the personnel, resources, and training necessary to ensure that the laws are adequately implemented and enforced," he said, stating that clear enforcement prior to the World Cup and Olympic games is crucial for success.