CARLOS AYRES

 carlos.ayres@maedaayres.com
+55 (11) 98711-0591
Portuguese, English and Spanish

INTRODUCTION

Mr. Ayres works with compliance, investigations and government enforcement since 2002, with an emphasis on Brazil and other countries of Latin America. He has coordinated several internal and independent corporate investigations in Latin America, Europe, and Africa, including some that were responsive to subpoenas by the U.S. Department of Justice (DOJ) and U.S. Securities and Exchange Commission (SEC) and other enforcement agencies.  Mr. Ayres has assisted several companies from different industries to implement and enhance their compliance programs and has conducted several anti-corruption due diligences of third parties and in the context of M&A transactions.

In the last years, Mr. Ayres has represented companies before Brazilian and international authorities such as the Federal Prosecutors Office, Office of the Comptroller General, Securities and Exchange Commission, Federal Police, State Police, Federal and State Courts, as well as before the DOJ and the SEC.

Mr. Ayres coordinates and teaches the Compliance Course at the School of Law of Fundação Getulio Vargas, in São Paulo where he also teaches at the White-Collar Crime Post-Graduation Program.

Together with partner Bruno Maeda, Mr. Ayres founded in 2010 the Anti-Corruption and Compliance Committee at the Brazilian Institute of Corporate Law (IBRADEMP). Acting as co-chair of IBRADEMP’s Anti-Corruption and Compliance Committee, Mr. Maeda and Mr. Ayres had an active role in promoting the discussion, both in Brazil and abroad, of Bill of Law 6,826/2010, which was approved by the Brazilian Congress in 2013 and became Brazil’s new Anti-Corruption Law (Law 12,846/2013, also known as the Clean Companies Act). The rapporteur Congressman publicly acknowledged Mr. Ayres and IBRADEMP’s contributions to the legislative process, mentioning that “the comments and recommendations were so valuable that they were incorporated into the Bill of Law.”

Mr. Ayres is the author of several articles and books published in Brazil and abroad, including the pioneer book “Temas de Anticorrupção e Compliance” (Themes of Anti-Corruption and Compliance), published in 2013 in Brazil. He is also a contributing writer of the FCPAméricas Blog. He is a regular speaker in national and international events and has spoken about compliance and anti-corruption in relevant forums, including at the Conference of the States Parties to the United Nations Convention against Corruption and at OECD.

Mr. Ayres served as Brazil’s Head of Delegation for ISO 37001 and was a member of the Editorial Group of the standard.

He was recognized as a leading practitioner by different specialized publications, including Chambers and the Global Investigations Review.

Before founding Maeda, Ayres & Sarubbi, he was a partner at the São Paulo office of a large Brazilian firm. Mr. Ayres worked in the Chicago office of an international law firm, between 2009 and 2010. In 2010, Mr. Ayres also worked at the Enforcement Division of the U.S. Securities and Exchange Commission in Washington/DC.

EDUCATION

• Fundação Getulio Vargas, Post-Graduation – Tax (São Paulo, Brazil)
• Universidade de Coimbra, Post-Graduation – Economic Crimes (São Paulo, Brazil)
• University of Florida, LL.M (Florida, USA)
• Pontifícia Universidade Católica de São Paulo, Bachelor of Laws (São Paulo, Brazil)

SIGNIFICANT ENGAGEMENTS

• Mr. Ayres was one of the lawyers leading the independent internal investigation conducted by Petrobras to evaluate the nature, extension and impact of the acts in the context of the “Car Wash” Operation.

• Assisted a major IT multinational company to obtain a declination from the authorities. In addition to coordinating an internal  investigation concerning allegations of potential violation of Brazilian procurement and anti-corruption laws, the work also  comprised assistance with remediation and mitigation measures, including in the termination of potentially implicated third parties, replacement of local management, and review of compliance policies and training.

• Conducted a large investigation for a multinational company in the pharmaceutical industry as a result of anonymous allegations of violation of anti-bribery laws. The work also included disclosures and negotiations with U.S. authorities.

• Successfully secured criminal conviction and restitution of assets to companies defrauded by their employees.

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