globalfindings/13-brazil-financial-trails-government-payments.md

# Brazil Investigation: Financial Trails, Government Payments, and Regulatory Capture
## Conselho Digital Financial Statements

No public financial statements exist for the Conselho Digital do Brasil (CNPJ `35.808.843/0001-01`). Searches combining "Conselho Digital" with "prestacao de contas," "relatorio financeiro," "balanco," and "receitas" returned zero results. The organization's website hosts no transparency or financial disclosure page.

Brazilian private associations face no legal obligation to publish financial statements publicly. Article 54 of the Codigo Civil requires the estatuto social to specify "the form of administrative management and the approval of the respective accounts," but this refers to internal approval by the general assembly of members. Publication obligations for financial statements in official journals apply to corporations (sociedades anonimas), not to associations.

The entity uses a Gold/Silver/Bronze membership tier structure. A Gold Associate receives voting rights in committees, seats on the Deliberative Council and Fiscal/Ethics Council, and the right to chair thematic committees. Companies X, 99, and Mercado Livre reportedly departed circa mid-2024. Current active members appear to be Google, Meta, Amazon, TikTok, Discord, Uber, Hotmart, and Kwai. No reporting has disclosed the monetary value of membership fees for any tier.

The Conselho Digital has never applied for OSCIP (Organizacao da Sociedade Civil de Interesse Publico) qualification, which would require enhanced financial transparency. Its estatuto social exists behind a "Conteudo Restrito" section on the website, inaccessible to the public.

The entity signed a formal Cooperation Agreement with the SPA (Secretaria de Premios e Apostas) of the Ministry of Finance on July 3, 2025, later extended through June 30, 2026. This agreement facilitates bilateral communication for removing illegal betting content. This is a cooperation agreement, not a financial transfer, so it does not appear in the Portal da Transparencia.

No Portal da Transparencia records exist for CNPJ `35.808.843/0001-01`. No Diario Oficial da Uniao mentions beyond the original registration. No investigative reporting has obtained the entity's actual financial records.

Source: SPA cooperation agreement https://www.gov.br/fazenda/pt-br/assuntos/noticias/2025/julho/spa-e-conselho-digital-firmam-acordo-para-combate-a-ilegalidade-no-mercado-de-apostas-de-quota-fixa
Source: Capital Digital tier structure https://capitaldigital.com.br/o-happy-hour-das-big-techs-com-autoridades-brasileiras/
Source: Agencia Publica https://apublica.org/2025/09/a-turma-do-block-como-as-big-techs-montaram-equipes-de-lobby-que-derrubam-projetos-de-lei/

## PGR Investigation into Fernando Maximo

Seven months after Deputy Guilherme Boulos (PSOL-SP) filed his criminal complaint on August 15, 2025, the PGR has taken no public action. No inquiry opened. No case forwarded to the STF. No press release issued. No declination or archival documented. No protocol number made public. The STF case database contains no case involving Fernando Maximo. Complete institutional silence.

Maximo meanwhile switched from Uniao Brasil to PL (Partido Liberal), with membership approved by national president Valdemar Costa Neto. PL launched him as a pre-candidate for the Senate from Rondonia on March 14, 2026, with Flavio Bolsonaro in attendance. A Parana Pesquisas poll from August 2025 showed him leading the Rondonia Senate race at 46.1%. Election to the Senate would extend his foro privilegiado (privileged forum jurisdiction at the STF) for another 8-year term.

Source: CartaCapital https://www.cartacapital.com.br/politica/boulos-vai-a-pgr-contra-deputado-por-conluio-com-big-techs-em-pl-sobre-criancas-na-internet/
Source: Poder360 Senate candidacy https://www.poder360.com.br/poder-eleicoes/pl-lanca-marcos-rogerio-ao-governo-de-rondonia-e-maximo-para-o-senado/
Source: Poder360 poll https://www.poder360.com.br/poder-pesquisas/dr-fernando-maximo-lidera-disputa-pelo-senado-em-ro-diz-pesquisa/

## Federal Police Investigation Status

## Fernando Maximo: Ambulance Fraud

No public reporting confirms formal indictment (indiciamento) or that the MPF has filed charges (denuncia) against Maximo in inquiry 2021.0002937. The case appears to remain at the police investigation stage. The PF found a shell company (Instruaud Sistema Integrado de Cuidados e Administracao) registered to two nurses at Hospital Santa Marcelina. One earned R$1,780.45/month. The other earned approximately R$5,000/month. One nurse purchased ten ambulances at R$350,000 each. The PF could not locate the nurse's residence, the company address, or the ambulances. The nurse's husband's account showed R$15,212,114 in deposits and R$15,000,000 in withdrawals.

Maximo also connected to Operation Poligrafo (COVID-19 test kit procurement fraud, R$10.5M for 100,000 rapid test kits) and Operation Ductil (suspicious COVID supply contracts exceeding R$21M). He was officially stated not to be a target in either operation. During PF testimony regarding the test kits, Maximo stated: "Iriam morrer de qualquer forma" ("They would die anyway"), referring to patients affected by delayed delivery of unregistered test kits. The TCE-RO (State Court of Accounts) separately fined him R$3,240 for irregularities in hospital laundry service contracts.

Source: Rondoniagora https://www.rondoniagora.com/policia/pf-encontra-laranjas-na-investigacao-do-aluguel-de-ambulancias-realizado-por-fernando-maximo
Source: Painel Politico https://www.painelpolitico.com/p/deputado-federal-fernando-maximo
Source: Tudo Rondonia https://www.tudorondonia.com/noticias/iriam-morrer-de-qualquer-forma-disse-fernando-maximo-a-pf-sobre-compra-de-kits-covid,122216.shtml

## Jadyel Alencar: COVID Supply Fraud: Now a Criminal Defendant

The MPF filed a formal criminal complaint (denuncia) which the 3rd Federal Court of Piaui accepted. As of June 2024, Jadyel Alencar became a criminal defendant (reu) alongside former state health secretary Florentino Neto (PT), former Fepiserh president Pablo Santos (MDB, state deputy), and Taciane Torres (Jadyel's then-wife). The charges are criminal association, illegal direct contracting, frustration of competitive bidding, and bidding/contract fraud. The MPF requests at least R$19 million in damages.

The case proceeds in the 3rd Court of the Judicial Section of Piaui, not under foro privilegiado, because the alleged conduct occurred before Alencar held his legislative mandate. Dimensao Distribuidora sold COVID supplies at prices 136%-438% above market. In March 2020, the company raised mask prices from R$11 to R$189 per box. The OAB and Procon do Piaui flagged this price gouging. The investigation drew on TCU and CGU audit reports.

Source: MPF formal charges https://www.mpf.mp.br/pi/sala-de-imprensa/noticias-pi/justica-federal-recebe-denuncia-do-mpf-por-fraudes-na-compra-de-materiais-para-combate-a-covid-19-no-piaui
Source: OitoMeia defendants https://www.oitomeia.com.br/noticias/politica/2024/06/10/deputados-piauienses-viram-reus-na-justica-federal/

## Jadyel Alencar: 2017 Conviction Appeal at TRF1

The TRF1's 4th Panel (4a Turma) began deliberations in July 2024. The rapporteur, Judge Marcelo Elias Vieira, voted to uphold the conviction. Judge Marcos Augusto concurred. Judge Cesar Jatahy requested a vista (review period). Two of three votes already favor upholding. No reporting confirms the final vote or publication of the judgment.

If the TRF1 formally publishes the confirmation, it constitutes a conviction by an orgao colegiado (collegiate body). Under LC 135/2010 (Lei da Ficha Limpa), article 1, I, alinea "e," item 1, receptacao qualificada is a crime against patrimony. A collegiate conviction triggers 8 years of ineligibility. This would bar Alencar from the 2026 Senate race his party is evaluating.

At the time of his 2022 candidacy, only a first-instance conviction existed, which does not trigger Ficha Limpa. No impugnation of his 2022 candidacy was found.

Source: Portal AZ TRF1 majority https://www.portalaz.com.br/colunas/39/direto-da-redacao/56923/jadyel-alencar-sofre-derrota-no-trf1-ja-ha-maioria-para-confirmar-con/
Source: TRF1 case page https://processual.trf1.jus.br/consultaProcessual/processo.php?proc=27626120144014000&secao=PI

## Additional Alencar Legal Exposure

Operation Jupiter (September 29, 2022): The PF seized R$24,000 in cash and campaign materials being transported from Teresina to Parnaiba during the 2022 campaign. The PF executed 5 search warrants against Alencar for suspected electoral corruption and electoral ideological falsity. He was elected despite this. No reporting found on the outcome.

Bom Jardim, Maranhao: The MP-MA filed an administrative improbity civil action in March 2019 against the former mayor and nine others including Alencar. R$6,080,185.31 in irregular medication and hospital supply contracts with Dimensao Distribuidora.

Child support: STF President Barroso overturned a Piaui court censorship order that had forced removal of O Estado de S. Paulo's coverage of Alencar's arrest order. No subsequent reporting confirms whether Alencar paid or was arrested.

Source: Piaui Hoje Operation Jupiter https://piauihoje.com/noticias/politica/candidato-jadyel-alencar-e-alvo-da-pf-por-suspeita-de-compra-de-votos-411718.html
Source: STF Barroso censorship reversal https://portal.stf.jus.br/noticias/verNoticiaDetalhe.asp?idConteudo=523740&ori=1

## Who Selected Jadyel Alencar as Rapporteur

Deputy Julio Cesar Ribeiro (Republicanos-DF), president of the Comissao de Comunicacao (CCOM), designated Alencar around April 8, 2025. Ribeiro was elected CCOM president unanimously on March 19, 2025. Both Ribeiro and Alencar belong to the same party, Republicanos. The CCOM president from the same party designated his party colleague as rapporteur of one of the session's most significant bills.

Alencar was designated before urgency was granted. The urgency request (REQ 1785/2025, filed by Deputy Laura Carneiro, PSD/RJ) was approved on August 19, 2025. months after the rapporteur designation. The bill was initially in ordinary CCOM processing, receiving 38 amendments during the April 2-14, 2025 amendment period.

No media coverage questioned the choice of a deputy with a criminal conviction, 93 judicial processes, R$48M in suspected money laundering, and a child support arrest order as rapporteur for child protection legislation. His 2017 first-instance conviction was a matter of public federal court record. The Ficha Limpa collegiate-body trigger had not yet been formally met.

Source: Camara CCOM president election https://www.camara.leg.br/noticias/1141881-julio-cesar-ribeiro-e-eleito-presidente-da-comissao-de-comunicacao/
Source: Rapporteur designation https://revistane.com.br/2025/04/15/jadyel-alencar-e-designado-relator-do-projeto-que-garante-protecao-a-criancas-e-adolescentes-na-internet/

## Persona-Serpro Partnership: Still Active

No evidence that Serpro has terminated, suspended, or publicly re-evaluated its partnership with Persona following the February 2026 exposure. Persona's website continues to market the Serpro integration. Persona's API documentation for Serpro Database Verifications remains active at docs.withpersona.com. Persona published a 2026 blog post referencing the Serpro integration as a Digital ECA compliance mechanism.

The ANPD has not opened any specific investigation into Persona. ANPD's 2025-2026 regulatory agenda includes biometric data regulation generally. No ANPD enforcement action targeting Persona was found.

Serpro itself faced a separate data scandal in February 2026: a Serpro employee seconded to the Federal Revenue Service accessed tax records of STF ministers and over 100 family members using a bot/automated tool. Federal Police executed four search warrants. STF Justice Alexandre de Moraes imposed maximum secrecy. This directly contradicts Serpro's official claim that employees "do not have access to the content of client agencies' databases."

Source: Persona API docs https://docs.withpersona.com/reference/retrieve-a-serpro-database-verification
Source: Persona blog https://withpersona.com/blog/brazil-digital-eca-age-assurance-regulation
Source: Serpro data breach https://www.serpro.gov.br/menu/noticias/noticias-2026/serpro-se-posiciona-sobre-investigacao-envolvendo-acesso-indevido-a-dados-fiscais

## Serpro Datavalid: Surveillance Infrastructure

## ABIN Accessed 76 Million Citizens' Data

In June 2020, Intercept Brasil published leaked documents showing ABIN (Brazil's intelligence agency) requested full access to Serpro's RENACH database covering 76 million Brazilians (36% of the population). Data requested: name, affiliation, CPF, address, telephone numbers, photo, and vehicle data including names of previous owners. Serpro assigned internal project code "11797 (Abin - Denatran Extraction)." Cost: R$330,000. Data provision scheduled May 2020 to May 2021. The government revoked the authorization after the Intercept expose.

Source: Intercept Brasil https://www.intercept.com.br/2020/06/06/abin-carteira-motorista-serpro-vigilancia/
Source: Convergencia Digital revocation https://sis-publique.convergenciadigital.com.br/cgi/cgilua.exe/sys/start.htm?infoid=54011&sid=18

## PRF Purchased Off-the-Books Copy of Entire Biometric Database

In May 2023, Intercept Brasil revealed the Federal Highway Police (PRF) signed a contract with Serpro in August 2022 to obtain biometric data (photos and signatures) of all 80+ million licensed drivers. Cost: R$205,722.80. The contract was not published in any transparency portal or the Official Gazette. The contract was subsequently suspended pending further assessment.

Source: Intercept Brasil https://www.intercept.com.br/2023/05/02/prf-desrespeita-lei-e-compra-copia-da-base-de-dados-biometricos-de-todos-os-motoristas-com-cnh-no-brasil/

## ANPD Found Datavalid Operates Without Full Legal Basis

ANPD Technical Note No. 39/2021/CGF/ANPD found that Datavalid operates without full legal support under the LGPD. The ANPD ordered immediate exclusion of data fields "CNH_Codigo_Situacao" and "CNH_Possui_Impedimento" because they do not serve to confirm identity. ANPD forwarded the Technical Note to the TCU within process TC 016.073/2019-3.

The MPDFT (Ministerio Publico do Distrito Federal) filed the original representation with TCU in June 2019 alleging Serpro illegally created Datavalid using CNH holder data without consent. TCU case rapporteur: Minister Bruno Dantas. No final judgment (acordao) found. The case appears to remain pending more than six years after filing.

Source: Capital Digital ANPD determination https://capitaldigital.com.br/anpd-datavalid-opera-sem-amparo-legal-da-lgpd-e-serpro-tem-de-mudar-o-servico/
Source: MPDFT representation https://www.mpdft.mp.br/portal/index.php/comunicacao-menu/sala-de-imprensa/noticias/noticias-2019/10987-mpdft-representa-contra-o-serpro-no-tcu

## Query Log Aggregation and Behavioral Profiling

Serpro retains query logs showing which company queried which CPF and when. These logs exist for billing, audit, and law enforcement purposes. The privacy notice confirms retention but does not specify duration. No published analysis examines whether aggregated Datavalid query patterns can build behavioral profiles. The structural capability exists: if a citizen's CPF is queried by an adult content platform, a gambling site, a dating app, and a financial service through Datavalid, the aggregated log reveals that citizen's digital behavior across platforms. The Digital ECA (effective March 17, 2026) will dramatically increase query volume as platforms must verify users' ages, creating a much larger dataset of CPF-to-platform mappings.

No publicly available RIPD (Relatorio de Impacto a Protecao de Dados Pessoais) for Datavalid was found, despite LGPD requiring one for processing that creates risks to civil liberties.

## Conecta+ Data Monetization

In 2025, the Federal Revenue Service authorized Serpro to share fiscal data (income, tax refunds) with private companies through the Conecta+ pilot project (Ordinance RFB 619/2025). A related Dataprev initiative explores a model where citizens authorize third parties to use their data in exchange for financial benefits. The state functions as "custodian and curator of informational assets."

Source: Capital Digital https://capitaldigital.com.br/receita-libera-serpro-para-compartilhar-dados-fiscais-no-conecta-e-reacende-debate-sobre-monetizacao-de-dados-pessoais/

## R$19.16M Meta Received from Federal Government

## SECOM Advertising Spend

SECOM (Secretaria de Comunicacao Social da Presidencia) is the largest single advertiser of political and social topics on Meta platforms in Brazil. The R$19.16M total at Portal da Transparencia reflects cumulative federal advertising payments. Year-by-year SECOM internet advertising totals across all platforms:

2023: R$47 million total. Meta (Facebook + Instagram) was the top recipient.
2024: R$42 million total (20% reduction). Meta again the top recipient.
2025: R$129.6 million, a record. Google received R$39 million. Meta received R$35.8 million.

In a single month (January-February 2025), SECOM paid R$1.1 million to Meta for 48 advertisements. Over a 90-day period ending early 2026, the government spent R$11.3 million on Facebook and Instagram ads.

Source: Nucleo government advertiser on Meta https://nucleo.jor.br/curtas/2024-03-21-governo-maior-anunciante-meta/
Source: Nucleo 2025 record spending https://nucleo.jor.br/interativos/2025-12-22-governo-lula-reg-maior-gasto-com-anuncios-na-internet-em-uma-decada-r-114-milhoes-em-2025/
Source: Poder360 R$1.1M in one month https://www.poder360.com.br/poder-governo/secom-gasta-r-11-milhao-com-anuncios-na-meta-em-1-mes/

## SECOM Advertising Agency Contracts

In April 2024, SECOM awarded R$197.7 million in digital communication contracts to four agencies: BR + Comunicacao (Consorcio BR&TAL), Usina Digital, IComunicacao Integrada, and Clara Servicos. These agencies manage the government's social media presence across Instagram, Facebook, TikTok, Kwai, LinkedIn, YouTube, and Pinterest.

BR+ was previously investigated by the CGU for overpricing and unverified services during 2023 SECOM digital work. Despite this, BR+ won the 2024 bid as part of the BR&TAL consortium. The TCU subsequently suspended the original bidding due to suspicions of confidentiality breach. These agencies serve as intermediaries placing ads on Meta platforms with government funds.

Source: Agencia Gov https://agenciagov.ebc.com.br/noticias/202404/secom-anuncia-empresas-vencedoras-licitacao-comunicacao-digital-governo
Source: Nucleo CGU investigation https://nucleo.jor.br/curtas/2024-04-24-secom-agencias-contrato-197-mi/

## Structural Conflict of Interest

The federal government simultaneously pays Meta tens of millions annually for advertising while Meta funds the Conselho Digital, which lobbies against platform regulation affecting Meta's business model. No direct evidence connects the R$19.16M in payments to Conselho Digital activities. Brazil has no lobbying disclosure law requiring companies to register activities, meeting topics, or influence spending. The structural relationship creates an unauditable feedback loop: public money flows to Meta as advertising revenue, Meta funds lobbying against public interest regulation, and no transparency mechanism captures either flow.

Source: Agencia Publica https://apublica.org/2025/09/a-turma-do-block-como-as-big-techs-montaram-equipes-de-lobby-que-derrubam-projetos-de-lei/

## Patri Consultancy: The Revolving-Door Factory

Patri Politicas Publicas & Public Affairs Ltda (CNPJ `54.567.201/0001-02`) was founded July 17, 1985 in Brasilia. It describes itself as "the largest Brazilian public affairs company." Approximately 70 employees including lawyers, journalists, social scientists, and international relations specialists. Offices in Brasilia, Sao Paulo, Belo Horizonte, and Washington DC (since 1996).

Founder Eduardo Carlos Ricardo (FGV-SP graduate) sits on the Board of Directors of the US Public Affairs Council. The firm claims it does not provide lobbying services and is a member of the UN Global Compact.

Both of the key Big Tech government relations directors in Brazil came from Patri. Murillo Laranjeira (Meta's Senior Director of Public Policy) was a partner at Patri for 7 years (January 2003 to June 2010). At Patri he worked on telecommunications, oil and gas, mining, entertainment, financial system, food, beverages, and tobacco. Marcelo Lacerda (Google's Director of Government Relations) was a partner at Patri for approximately 8 years (December 2004 to June 2013). Before Patri he worked at the Ministry of Environment during the FHC and Lula administrations (1997-2004). Lacerda left Google and became Chairman of the Board at Magnopus (deep tech, working with Disney, Google, Meta, Amazon, NASA) in April 2025.

No evidence connects Patri to age verification companies. No corruption investigations involving Patri were found.

Source: Patri website https://patri.com.br/sobre
Source: Patri CNPJ https://cnpj.biz/54567201000102
Source: Metropoles https://www.metropoles.com/blog-do-noblat/quem-sao-os-lobistas-de-google-e-meta-contra-o-pl-das-fake-news

## Dario Durigan: From Meta/WhatsApp to Minister of Finance

Dario Durigan served as Director of Public Policies at WhatsApp (Meta) from 2020 to 2023. He became Executive Secretary of the Ministry of Finance in June 2023. On March 19, 2026, five days before this research was compiled, President Lula named him Minister of Finance, replacing Fernando Haddad.

A former Meta executive now runs Brazil's Finance Ministry. The Finance Ministry oversees SECOM advertising budgets, tax policy affecting tech companies, and the SPA (Secretaria de Premios e Apostas) that signed the cooperation agreement with Conselho Digital. The man in charge of all of this spent three years at Meta/WhatsApp.

Source: O Tempo https://www.otempo.com.br/politica/governo/2026/3/20/saiba-quem-e-dario-durigan-nomeado-como-novo-ministro-da-fazenda-do-governo-lula
Source: Racismo Ambiental https://racismoambiental.net.br/2025/02/26/big-techs-infiltram-se-no-ministerio-da-fazenda/

## Dalton Vitoriano Locatelli: Full Client List

Locatelli is partner, administrator, or procurador in 178 companies (160 currently active). First partnership: December 14, 1973. He operates through HLB Brasil, part of the HLB global network ($2.73B revenue, 153 countries).

Confirmed tech and media companies: Facebook Miami Inc (procurador), Akamai Tecnologias e Servicos do Brasil (CNPJ `13.718.756/0001-12`), Warner Bros Discovery Brasil (CNPJ `03.390.444/0001-79`), NortonLifeLock Brasil, Seagate Brasil, Universal Studios International Television do Brasil, Msg Global Solutions do Brasil, Dealogic Solucoes Brasil, Robert Half Trabalho Temporario, Clara Pagamentos.

Locatelli does not represent Google, Amazon, TikTok, Apple, or Microsoft Brazilian entities. No connection to age verification companies. His role is that of a professional nominee providing legal representation through HLB Brasil's Business Process Solutions offering.

Source: CNPJ Services https://cnpj.services/qsa/dalton-vitoriano-locatelli
Source: UK Companies House https://find-and-update.company-information.service.gov.uk/officers/7cQZX0801aR7ioJ-ZkPqECC15b8/appointments

## Bruna Marques Futuro: Added, Not Replacing

Futuro was added as an additional administrator. Conrado Leister remains in place. The current QSA shows three entries: Futuro (entered February 10, 2026), Leister (entered November 14, 2018), and Facebook Miami Inc (foreign partner, represented by Locatelli).

Historical administrators include Alexandre Hohagen, Leonardo Tristao, and Diego Dzodan (assumed June 2015). Meta added a second administrator with tax and compliance expertise 35 days before Digital ECA enforcement. As Head of International Tax for Latin America, Futuro's addition structures legal/fiscal liability for the new R$50M-per-violation regime.

Source: cnpj.biz https://cnpj.biz/13347016000117
Source: ITR Global Tax 50 https://www.internationaltaxreview.com/article/2azqsu44hcmwfroh9h4w0/itr-global-tax-50-2022-bruna-futuro