Luis Wielewicki of Sampaio Ferraz Advogados in Sao Paulo said: “It`s like an annex. An individual is bound by the leniency of the company, which is different from any other jurisdiction I know. In addition, the corporation must also express its interest in cooperating in the investigation of the prejudicial act, terminate its participation in the practice under consideration at the time of the presentation of the proposed agreement, acknowledge its participation in the unlawful act and, finally, participate fully and sustainably in the investigation. On the public administration side, the Comptroller General of the Union -CGU is the body responsible for concluding leniency agreements arising from Brazil`s anti-corruption law, under the federal executive and in harmful acts against the foreign public administration. Hey, Maura! Your point is very important. Some argue that institutional diversity in Brazil has contributed to the recent successes of the fight against corruption. (For example, in English, Carson and Prado, 2016 – www.sciencedirect.com/science/article/pii/S1062976916300564). In theory, institutional diversity not only offers some controls to others, but also creates a race, a quarrel for results. However, in practice, these institutions are constantly competing for more power and relevance, resulting in constant coordination problems and a confusing accountability system. It is difficult to know which of these effects predominates. With regard to leniency agreements in particular, I think that this type of institutional diversity creates more problems than benefits, at least in the Brazilian reality. 2) If individuals also apply for a legal motion, leniency negotiations should be conducted in parallel or after the negotiation of individuals` arguments (note that a leniency agreement signed under the Clean Companies Act does not protect individuals from criminal liability under the Brazilian Penal Code) (guideline 1.