Earlier today, the Office of the Comptroller General in Brazil, Controladoria-Geral da União (“CGU”), issued a sweeping directive barring government officials from accepting offers to attend or participate in the upcoming 2014 FIFA World Cup events set to begin in Brazil on June 12, 2014. This CGU directive is consistent with the existing obligations of businesses under Brazil’s recently enacted Anti-Corruption Law, No. 12,846/2013, the US Foreign Corrupt Practices Act (“FCPA”), the UK Bribery Act (“Bribery Act”), and the anti-corruption laws of most countries.

The CGU directive provides companies dealing with corporate hospitality surrounding the World Cup with a valuable response to Brazilian government officials seeking tickets to see Messi, Neymar, Ronaldo, Suarez, Xavi, and, of course, America’s own Clint Dempsey.

I. The CGU Directive

Consistent with Brazil’s anti-corruption legislation, the CGU’s directive prohibits federal public agents from accepting any invitations, tickets, transportation or hotel offers to watch matches or participate in World Cup events. Officials may, however, accept invitations or tickets in limited circumstances...