Merger control in Brazil: overview

A Q&A guide to merger control in Brazil.

The Q&A gives a high level overview of merger control, regulatory framework and regulatory authorities, relevant triggering events and thresholds in Brazil. It also covers notification requirements, procedures and timetables, publicity and confidentiality, third party rights, substantive test, remedies, penalties, appeals, joint ventures and proposals for reform.

For information on restraints of trade, monopolies and abuses of market power in Brazil, visit Restraints of trade and dominance in Brazil: overview.

For a full list of jurisdictional Merger Control Q&As visit www.practicallaw.com/mergercontrol-guide. For a full list of jurisdictional Restraints of Trade and Dominance Q&As visit www.practicallaw.com/restraintsoftrade-guide.

For a full list of jurisdictional Cartel Leniency Q&As, which provide a succinct overview of leniency and immunity, the applicable procedure and the regulatory authorities in multiple jurisdictions, visit www.practicallaw.com/leniency-guide.

Leonardo Canabrava, Lucas E.F.A. Spadano, Bruno Herwig Rocha Augustin, Bruno Alves Delpupo, Campos, Fialho, Canabrava, Borja, Andrade, Salles Advogados
Contents

Regulatory framework

1. What (if any) merger control rules apply to mergers and acquisitions in your jurisdiction? What is the regulatory authority?

Regulatory framework

The merger control rules are provided for in Law 12.529/2011. Additionally, the Administrative Council for Economic Defence (Conselho Administrativo de Defesa Econômica) (CADE) has published several resolutions regulating specific aspects of Law 12.529/2011. For merger review, the most relevant resolutions are:

  • Resolution 1/2012 (CADE's internal rules).

  • Resolution 2/2012 (rules on the notification of transactions).

An English version of Law 12.529/2011 is available on CADE's website (www.cade.gov.br/upload/LAW%20N%C2%BA%2012529%202011%20(English%20version%20from%2018%2005%202012).pdf).

Regulatory authority

The anti-trust regulatory authority is CADE, which has three mains divisions:

  • The Administrative Tribunal for Economic Defence.

  • The General Superintendence.

  • The Department of Economic Studies.

The General Superintendence plays a role in the analysis of mergers. It receives all the approval requests and decides the procedure they will follow (whether or not it is fast-track) or if the case should be sent to the Administrative Tribunal for Economic Defence's decision (see Question 4). Within this system, the majority of mergers are decided by the General Superintendence.

See box, The regulatory authority.

 

Triggering events/thresholds

2. What are the relevant jurisdictional triggering events/thresholds?

Triggering events

Law 12.529/2011 adopted a pre-merger control system. This means that the Administrative Council for Economic Defence (Conselho Administrativo de Defesa Econômica) (CADE) must approve mergers before they are implemented.

The following types of transaction are subject to CADE's review:

  • Mergers.

  • Acquisition of assets, control or parts of a company.

  • Incorporation.

  • Associative contracts, joint ventures and consortia.

Notifiable associative contracts are those with a risk-sharing arrangement as well as a vertical or horizontal co-operation scheme (with a duration exceeding two years) that result in an interdependent relationship between the contracting parties.

Associations created for the purpose of participating in public bids are not subject to merger control.

Specific rules apply to partial acquisitions of companies and the subscription of bonds, debentures and other securities convertible into shares.

Partial acquisitions must be notified if there is an acquisition of:

  • Control (individual or shared control).

  • 20% or more of the shares or voting capital (if the target company and the companies of the economic group of the acquirer do not compete or perform activities in vertical related markets).

  • 5% or more of the shares or voting capital (if the target company and the companies of the economic group of the acquirer compete in the same market or perform activities in vertical related markets). Any additional acquisitions that result in an increase of 5% of the shares or voting capital must also be notified.

The subscription or acquisition of bonds, debentures and other securities convertible into shares are notifiable if the future conversion:

  • Of the bonds, debentures or other securities results in the control of the target company or the criteria for notification of partial acquisition are met.

  • Grants the acquirer rights to participate in relevant market decisions, such as:

    • the right to participate in administrative and management bodies;

    • the right to choose administrators, directors or any relevant position in the company; and

    • veto rights.

Thresholds

The notification thresholds are based on annual turnover or on the parties' total revenue in Brazil.

The notification thresholds are:

  • The economic group of one party must have had a gross revenue or business turnover in Brazil of at least BLR750 million in the previous fiscal year.

  • The other economic group must have had at least BRL75 million of gross revenue or business turnover in Brazil in the previous fiscal year.

The gross revenue or turnover determination must take into account all the companies that form the economic group. CADE has a specific concept of economic group, which comprises the following entities:

  • Entities subject to common control.

  • All the entities in which any of the companies subject to a common control holds, directly or indirectly, at least 20% of the shares or voting capital.

Additionally, special rules apply for investment funds falling within the concept of economic group. The economic group includes:

  • The fund directly involved in the transaction.

  • The economic group of the investors holding, directly or indirectly, 50% or more of the quotas of the fund directly involved in the transaction (either individually or under a shareholder agreement).

  • The portfolio companies controlled by the entities listed in the above two bullets or in which these entities hold, directly or indirectly, at least 20% of the shares or voting capital.

 

Notification

3. What are the notification requirements for mergers?

Mandatory or voluntary

Notification is mandatory if the relevant threshold is fulfilled (see Question 2).

If a transaction does not fulfil the thresholds then the Administrative Council for Economic Defence (CADE) can request the notification up to one year after the transaction is closed.

Timing

Law 12.529/2011 adopted a pre-notification merger system. A merger is notified prior to its implementation and preferably after the signing of a binding document that sets out the conditions of the transaction.

CADE has 240 days (extendable up to 330 days) to decide on the merger.

Pre-notification formal/informal guidance

CADE offers informal guidance in non-fast track cases.

Formal guidance is available through a specific procedure. This procedure must relate to a specific factual situation in order for CADE to interpret the laws and regulations applied to it.

Additionally, CADE has also published guides on specific topics. A guide on gun jumping has been published and a first draft of a Compliance Guide and a Guide on CADE´s Leniency Programme, subject to commentaries from interested parties, was released by CADE.

Responsibility for notification

Both parties are responsible for the notification.

Relevant authority

CADE is the relevant authority to approve mergers.

Form of notification

CADE's Resolution 2/2012 provides for two notification forms:

  • Annex I contains a form for non-fast-track cases.

  • Annex II contains a form for fast-track cases.

Resolution 2/2102 is available on CADE's website (www.cade.gov.br/upload/Resolu%C3%A7%C3%A3o%202_2012%20-%20An%C3%A1lise%20Atos%20Concentra%C3%A7%C3%A3o.pdf).

Filing fee

Submitting a notification to CADE requires a filing fee of BRL45,000. From 1 January 2016, the filling fee's value will increase to BLR85,000.

Since there are no rules regarding who pays the fee, this decision is left to the parties.

Obligation to suspend

The pre-merger notification system requires parties to suspend the transaction until a final decision by CADE is made.

CADE's Administrative Tribunal for Economic Defence can allow the implementation of the transaction prior to CADE's approval in certain situations. However, this clearance is subject to the implementation of conditions that ensure the reversibility of the transaction.

 

Procedure and timetable

4. What are the applicable procedures and timetable?

For an overview of the notification process, see flowchart, Brazil: merger notifications ( www.practicallaw.com/5-504-4341) .

Initially, the General Superintendence analyses the documents received and requests the parties to provide any additional information necessary for the anti-trust analysis to proceed.

Once the General Superintendence concludes that the notification is accompanied by all the necessary information to initiate the anti-trust analysis of the operation, a public notice will be published in the Official Journal.

After publication in the Official Journal, the General Superintendence proceeds with the anti-trust analysis. The time limit for a final decision of the General Superintendence varies depending on the complexity of the transaction and the necessity of additional information (additional requests for information are not unusual).

The possible outcomes of the General Superintendence's evaluation are:

  • Unconditional approval. Here a public notice indicating the unconditional approval is published in the Official Journal. A period of 15 days must then pass before the implementation of the transaction. Within this period, any interested party or a member of Administrative Council for Economic Defence's (Conselho Administrativo de Defesa Econômica) (CADE) Administrative Tribunal for Economic Defence can object to the approval and ask CADE's Administrative Tribunal for Economic Defence to analyse it.

  • Conclusion of an agreement on merger control (AMC). The AMC establishes remedies with the aim of eliminating anti-competitive effects of the transaction (see Question 10).

  • Conditional approval, rejection and final conclusion indicating the lack of information regarding the impact of the transaction in the market. Here the merger is submitted to the Administrative Tribunal for Economic Defence's final decision.

There are no defined deadlines for each phase of the investigation. The overall analysis of CADE must be completed in 240 days (extendable up to 330 days). If CADE fails to analyse the merger within this period, automatic clearance is given to the merger.

The average time for CADE's analysis has been significantly lower than 240 days. The average time in 2014 was 31 days. The average time for fast-track cases analysis was 20 days. For non-fast-track cases, the average was 84 days.

 

Publicity and confidentiality

5. How much information is made publicly available concerning merger inquiries? Is any information made automatically confidential and is confidentiality available on request?

Publicity

Generally, all government procedures must be made publicly available. However, specific relevant information and documents related to the parties, if requested, can be submitted to confidential treatment.

The Administrative Council for Economic Defence's (Conselho Administrativo de Defesa Econômica) (CADE) internal rules indicate the information that can or cannot be subject to confidential treatment.

Automatic confidentiality

In order to obtain confidentiality treatment, it must be requested.

Confidentiality on request

Resolution 1/2012 (CADE's internal rules) indicates the information subject to confidential treatment, such as:

  • Revenues and turnover.

  • Documents related to the transaction.

  • Market share of the parties.

 

Rights of third parties

6. What rights (if any) do third parties have to make representations, access documents or be heard during the course of an investigation?

Representations

Third parties can evidence their position regarding the merger after the publication of the public notices at the initial stage of the investigation. Additionally, third parties can also file an appeal to the Administrative Tribunal for Economic Defence within 15 days after the decision of the General Superintendence.

Document access

Generally, the procedure is public and third parties can access most information so long as it is not confidential.

Be heard

Third parties can answer the Administrative Council for Economic Defence's (CADE) information requests and any relevant information concerning market shares and other business specificities.

 

Substantive test

7. What is the substantive test?

Mergers will be rejected if:

  • The transaction implies the elimination of competition on a substantial part of a market.

  • As a result of the merger, a dominant position in the market is created or reinforced.

  • The transaction results in market domination.

 
8. What, if any, arguments can be used to counter competition issues (efficiencies, customer benefits)?

The Administrative Council for Economic Defence (CADE) can approve transactions, despite any anti-competitive effects, if the merger achieves the following results:

  • An increase in the productivity or competitiveness.

  • An increase in the quality of goods and services.

  • It contributes to efficiency and technological and economic development.

Additionally, a relevant part of these results must be shared with the consumers.

 
9. Is it possible for the merging parties to raise a failing/exiting firm defence?

The failing firm defence is not provided for in the Law 12.529/2011 (and the resolutions governing specific aspects of the Law) or in the Horizontal Merger Guidelines currently used by the Administrative Council for Economic Defence (CADE).

The use of the failing firm defence in order to justify the approval of mergers is rare and CADE has accepted this defence on only one occasion, under the former Anti-Trust Law of Brazil in 2007.

 

Remedies, penalties and appeal

10. What remedies (commitments or undertakings) can be imposed as conditions of clearance to address competition concerns? At what stage of the procedure can they be offered and accepted?

If the Administrative Council for Economic Defence (CADE) concludes that a merger has potential anti-competitive effects, it can either reject the operation as whole or approve it with restrictions. These restrictions can be of a behavioural or structural nature (or both).

Law 12.529/2011 expressly provides for the following remedies (other remedies can be imposed):

  • The selling of specific assets or assets comprising a specific economic or industrial activity.

  • The split of a company.

  • Sale of company control.

  • The accounting and financial separation of economic activities.

  • Compulsory licensing of intellectual property rights.

If anti-competitive effects are present in a merger, the parties or the General Superintendence can conclude an agreement on merger control (AMC) addressing specific remedies (behavioural or structural). The AMC can be proposed by the parties from the notification until 30 days after the final decision by the General Superintendence.

Although it is expected that CADE will elaborate on a guide on remedies in the near future, the rules currently in force do not provide detailed guidance regarding the enforcement of remedies. With AMCs, the compliance standards have been defined on a case-by-case basis.

 
11. What are the penalties for failing to comply with the merger control rules?

Failure to notify correctly

The Administrative Council for Economic Defence's (CADE) Administrative Tribunal for Economic Defence can review its decisions if they are taken on the basis of false or misleading information presented by the parties, in the case of non-compliance with any of the obligations assumed by the parties or if the intended benefits of the merger are not achieved (see Question 8).

Besides the revision of the decision, the parties are subject to fines ranging from BRL60,000 to BRL60 million. Additionally, an administrative proceeding can be initiated against the parties.

Implementation before approval or after prohibition

If the parties proceed to the implementation of the merger prior to CADE's approval, CADE can render the merger void and subject parties to fines and behavioural remedies.

The prohibition of prior implementation, known as gun jumping, is very recent in Brazil (since it was implemented through Law 12.529/2011). Recently, CADE published a gun jumping guide indicating what conduct prior to CADE's approval are not allowed.

The fines applied for gun jumping range from BRL60,000 to BRL60 million although the fines applied in cases of gun jumping have been significantly lower than BRL60 million].

Additionally, behavioural remedies can be imposed. In one case (process 08700.010394/2014-32), after finding that gun jumping took place, the buyer was prohibited from using the trade mark acquired in the merger during two years.

An administrative process can also be initiated against the parties.

Failure to observe

CADE's decision (including the implementation before approval or after prohibition, mentioned above) constitutes an extrajudicial title. Here the judge grants specific performance of the obligation or determines other measures to ensure the practical result equivalent to compliance.

The conversion of specific obligations (remedies) to compensation for losses or damages are only admissible if specific performance or obtainment of the corresponding desired result is impossible.

A far more drastic approach envisaged in the Law 12.529/2011 allows a judge to authorise intervention in the company when required to ensure specific performance by appointing an intervener.

 
12. Is there a right of appeal against the regulator's decision and what is the applicable procedure? Are rights of appeal available to third parties or only the parties to the decision?

Rights of appeal

The decision of the General Superintendence is subject to appeal by any third party or, regarding regulated markets, by the competent regulatory agency.

The final decisions of the Administrative Council for Economic Defence's (CADE) Administrative Tribunal for Economic Defence, on the other hand, are not subject to appeal in the administrative instance. Judicial review of the Administrative Tribunal for Economic Defence's decision is possible.

Procedure

The decision of the General Superintendence is subject to appeal to CADE's Administrative Tribunal for Economic Defence within 15 days of its publication.

Five days from the receipt of the appeal, the case must be:

  • Submitted to trial.

  • Reviewed by the Reporting Commissioner responsible for the case, who can ask for performance of complementary fact-finding.

  • Dismissed at the appeal.

The parties of the merger can submit their views within five days of receipt of the appeal or the complementary fact-finding report by the Administrative Tribunal for Economic Defence.

The final decision of CADE's Administrative Tribunal for Economic Defence cannot be subject to an administrative appeal. A judicial law suit against CADE's Administrative Tribunal for Economic Defence decision does not have a predictable timescale for conclusion.

Third party rights of appeal

Third parties can appeal the decision of the General Superintendence.

 

Automatic clearance of restrictive provisions

13. If a merger is cleared, are any restrictive provisions in the agreements automatically cleared? If they are not automatically cleared, how are they regulated?

Parties must present copies of the agreements structuring the merger and, specifically, of restrictive clauses. In the anti-trust analysis carried out by Administrative Council for Economic Defence (CADE) of the merger as whole, these clauses are evaluated and a possible outcome may be a requirement to modify these clauses if CADE finds that they do not meet the legal test (see Question 7).

 

Regulation of specific industries

14. What industries (if any) are specifically regulated?

Law 12.529/2011 does not provide any distinction on the different types of industries. However, regulated industries such as energy, banking, oil and gas, civil aviation and telecoms have specific rules that can apply to certain mergers.

Transactions in the financial sector have been subject to an important discussion concerning the authority competent to clear mergers. On one hand, the Brazilian Central Bank (BACEN) maintains it has competence to analyse mergers in the financial sector, due to a prevision contained in Law 4.594/1964. The Administrative Council for Economic Defence (CADE), on the other hand, understands that Law 12.529/2011 established its competence, irrespective of any industry sector, including the financial industries.

After a long judicial dispute, the Brazilian Supreme Court decided in 2014 that BACEN has the competence to analyse mergers in the financial sector.

 
15. Has the regulatory authority in your jurisdiction issued guidelines or policy on its approach in analysing mergers in a specific industry?

There are no specific guidelines for merger approach in specific industries or economic sectors.

 

Joint ventures

16. How are joint ventures analysed under competition law?

Joint ventures are listed as transactions that require the Administrative Council for Economic Defence's (CADE) prior approval. Generally, joint ventures are notifiable in the same way as other transactions discussed above (see Question 3).

However, due to their nature, different standards are applied to joint ventures, such as the application of criteria to determine if non-compete clauses may affect competition. Therefore, non-compete clauses can last as long as the joint venture exists and for an additional period of five years after the joint venture has come to an end (the general rule provides that non-compete clauses can last for a period of five years) (see Question 13).

 

Inter-agency co-operation

17. Does the regulatory authority in your jurisdiction co-operate with regulatory authorities in other jurisdictions in relation to merger investigations? If so, what is the legal basis for and extent of co-operation (in particular, in relation to the exchange of information, remedies/settlements)?

The Administrative Council for Economic Defence (CADE) has established several agreements to co-operate with others jurisdictions, such as:

  • Argentina.

  • Canada.

  • Chile.

  • China.

  • Colombia.

  • The US.

  • Ecuador.

  • France.

  • Japan.

  • Korea.

  • Peru.

  • Portugal.

  • Russia.

  • The EU.

  • The Mercosur.

Additionally, agreements were signed with international institutions, such as:

  • The World Bank.

  • The Inter-American Development Bank.

The majority of these agreements establish co-operation mechanisms through:

  • Exchange of information.

  • Bilateral confidentiality.

  • Law enforcement requests.

  • Other procedures.

These mechanisms and procedures aim to intensify joint investigations and allow countries to develop best practices in different fields.

The international co-operation agreements currently in force are available at www.cade.gov.br/Default.aspx?2202020e12f033172912.

 

Recent mergers

18. What notable recent mergers or proposed mergers have been reviewed by the regulatory authority in your jurisdiction and why is it notable?

The Administrative Council for Economic Defence (CADE) reviewed the acquisition of Anhanguera by the Kroton Group, in the education market. The case discussed the relevance of the differences between distance learning and traditional education methods in the definition of the relevant market of education.

CADE reviewed the acquisition of Solvay by Braskem. The case was relevant since it was the first transaction blocked by CADE under the new law.

The transaction between Holcim and Lafarge was important due to the significance of remedies imposed by CADE for the transaction to be cleared.

 

Proposals for reform

19. Are there any proposals for reform concerning merger control?

The Brazilian Competition System has been recently reformulated with the enactment of Law 12.529/2011. Since then, specific procedural and substantive aspects of the Law have been subject to resolutions enacted by the Administrative Council for Economic Defence (CADE).

Currently, there are no reform proposals. However, CADE can issue new regulations and guides to address specific concerns in the near future, such as:

  • New horizontal and vertical mergers guidelines.

  • Resolutions defining the concept of control.

  • Guide on anti-trust compliance.

  • Guide on the implementation of anti-trust remedies.

 

Online resources

Council for Economic Defence (Conselho Administrativo de Defesa Econômica) (CADE)

W www.cade.gov.br/Default.aspx?b879bb44c847c960f354

Description. The website is in Portuguese, but it includes the most relevant applicable legislation officially translated into English.

Secretary for Economic Monitoring (Secretária de Acompanhamento Econômico) (SEAE)

W www.seae.fazenda.gov.br

Description. The Secretariat for Economic Monitoring is responsible for promoting competition in government agencies and in society. SEAE's main responsibilities are set out in Article 19 of Law 12.529/2011.

Brazilian Institute for Economic Defence, Consumers and International Trade (Instituto Brasileiro de Estudos de Concorrência, Consumo e Comércio Internacional) (IBRAC)

W www.ibrac.org.br

Description. IBRAC is a non-profit private entity that aims to foster the development of research, studies and debates involving competition, consumer law issues and international trade. It maintains regular dialogue with government authorities, society and the community of professionals working with competition law in Brazil.

Brazilian System for Protection of Competition (Sistema Brasileiro de Defesa da Concorrência) (SBDC)

W www.cade.gov.br and www.seae.fazenda.gov.br

Description. The SBDC consists of the Administrative Council for Economic Defence (CADE) and the Secretary for Economic Monitoring (SEAE) both within the Ministry of Finance.



The regulatory authority

Council for Economic Defence (Conselho Administrativo de Defesa Econômica) (CADE)

W www.cade.gov.br/Default.aspx

Outline structure. The CADE consists of:

  • An Administrative Tribunal of Economic Defence.

  • A General Superintendence.

  • A Department of Economic Studies.

Responsibilities. The CADE is the regulatory authority responsible for the enforcement of the Brazilian Competition Law (Law No. 12.529 of 30 November 2011).

Procedure for obtaining documents. Most relevant documents, pursuant to the publicity law enforced by all government organisations, are available on CADE's website, via a special search mechanism. Legislation concerning CADE's authority is also available on the website. All documents can be accessed, with the exception of confidential ones (see Question 5. Publicity and Confidentiality) and those related to cases subject to confidential treatment.

CADE's searching mechanism (Integrated Electronic System) (SEI) can be found at http://sei.cade.gov.br/sei/institucional/pesquisa/processo_pesquisar.php?acao_externa=protocolo_pesquisar&acao_origem_externa=protocolo_pesquisar&id_orgao_acesso_externo=0.

Secretary for Economic Monitoring (Secretaria de Acompanhamento Econômico) (SEAE)

W www.seae.fazenda.gov.br

Outline structure. The SEAE is composed of three specific divisions:

  • Sub-secretary of Economic Monitoring and Competition Law (Subsecretária de Análise Econômica e Advocacia da Concorrência) (SUCON).

  • Sub-secretary of Regulation and Infrastructure (Subsecretária de Regulação e Infra-Estrutura) (SUINFRA).

  • Sub-secretary of International Competition Law and Popular Economy Defences (Subsecretária de Concorrência Internacional e Defesa da Economia Popular) (SUDEP).

Responsibilities. The SEAE promotes competition in government agencies and in society and participates in the elaboration of norms regulating competition.

Procedure for obtaining documents. As a result of the obligations established by the Publicity Law (mainly the obligation of publicity of documents, which must be observed by government organisations), most relevant documents are available on SEAE's website (www1.seae.fazenda.gov.br/LITTERA/BuscaProcessos.aspx and www.seae.fazenda.gov.br/legislacao).



Contributor profiles

Leonardo Canabrava, Partner

Campos, Fialho, Canabrava, Borja, Andrade, Salles Advogados

T +55 31 4501 7796 / +55 11 4064-7016 / +55 31 9950-9609
E lcanabrava@camposfialho.com.br
W www.camposfialho.com.br

Professional qualifications. Brazil, lawyer

Areas of practice. Economic and competition law; arbitration; commercial contracts; project finance; infrastructure; complex litigation.

Languages. English, French

Professional associations/memberships. Member of CBar (Comitê Brasileiro de Arbitragem); member of CAMARB (Câmara de Arbitragem Empresarial); member of ICC (International Chamber of Commerce).

Lucas E.F.A. Spadano, Partner

Campos, Fialho, Canabrava, Borja, Andrade, Salles Advogados

T +55 11 4064 7013 / +55 11 99693-6253
E lspadano@camposfialho.com.br
W www.camposfialho.com.br

Professional qualifications. Brazil, lawyer

Areas of practice. Economic and competition law; mergers and acquisitions; international trade; foreign investment; intellectual property, technology and innovation.

Languages. English, Spanish

Professional associations/memberships. Member of CBar (Comitê Brasileiro de Arbitragem); member of CAMARB (Câmara de Arbitragem Empresarial); member of ICC (International Chamber of Commerce).

Bruno Herwig Rocha Augustin, Associate

Campos, Fialho, Canabrava, Borja, Andrade, Salles Advogados

T +55 31 4501-7828 / +55 31 9196-3850
E bruno.augustin@camposfialho.com.br
W www.camposfialho.com.br

Professional qualifications. Brazil, lawyer

Areas of practice. Economic and competition law; international trade.

Languages. English, German

Professional associations/memberships. Brazilian Bar.

Bruno Alves Delpupo, Associate

Campos, Fialho, Canabrava, Borja, Andrade, Salles Advogados

T +55 31 4501 785 / +55 31 7337 9996
E bruno.delpupo@camposfialho.com.br
W www.camposfialho.com.br

Professional qualifications. Brazil, lawyer

Areas of practice. Economic and competition law; international trade.

Languages. English, German

Professional associations/memberships. Brazilian Bar.


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