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 | Investigations Dataset

Stanford Foreign Corrupt Practices Act Clearinghouse a Collaboration with Sullivan & Cromwell LLP

Investigations Dataset

 
Investigation into GOL Linhas Aereas Inteligentes' Activities in Brazil in 2012 and 2013 · GOL Linhas Aereas Inteligentes S.A.

Information & Summary

Investigation into GOL Linhas Aereas Inteligentes' Activities in Brazil in 2012 and 2013

Related FCPA Matter:   GOL Linhas Aereas Inteligentes' Involvement in Brazil in 2012 and 2013 Information

Information & Summary

Investigation Name:    Investigation into GOL Linhas Aereas Inteligentes' Activities in Brazil in 2012 and 2013

Trend:    None

Type of investigation:    Internal, SEC, DOJ

Other Agencies Investigating/Assisting with SEC/DOJ Investigation:   

  • Brazilian Tax Authority

Whistleblower:    Unknown

Summary

GOL Linhas Aéreas Inteligentes S.A. (GOL), incorporated and with principal offices in Brazil, is a Brazilian airline. Its American Depositary Shares are traded on the New York Stock Exchange.

On October 21, 2016, GOL announced that the Brazilian tax authorities had requested information regarding certain expenditures that GOL had made in 2012 and 2013. In response to this request, the company initiated an internal investigation. In December, GOL retained U.S. and Brazilian counsel to further the investigation.

Also in December 2016, GOL entered into a leniency agreement with the Brazilian Federal Public Ministry under which the company agreed to pay fines totaling R$12 million and improve its compliance policies and procedures and the Federal Public Ministry agreed it would not prosecute the company for "acts of administrative impropriety and related acts involving politically exposed persons" or other possible acts that would be uncovered by the ongoing investigation by outside counsel. GOL reported the investigation and the leniency agreement to the SEC, DOJ, and the Brazilian securities commission.

In its 20-F filed on May 1, 2017, GOL disclosed that the internal investigation had concluded in April 2017. The investigation revealed that certain payments had been made to politically exposed persons. GOL promised to report the conclusions of its investigation to the relevant authorities.

Though subsequent company filings never confirmed whether the DOJ and SEC opened independent investigations following GOL's self-reporting of its internal investigation, on September 15, 2022, both the DOJ and SEC announced enforcement actions against the company.

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