By Brazil Stock Guide – Brazil’s Administrative Council for Economic Defense (CADE) has opened a new investigation into major global soy traders for alleged collusion under the Soy Moratorium, the voluntary pact that bans the purchase of soybeans grown on deforested land in the Amazon after July 2008.
The Superintendence-General (SG) of CADE launched an Administrative Inquiry (No. 08700.011414/2025-45) this week to examine whether executives from some of the world’s largest grain companies coordinated purchasing practices and embargo procedures in ways that may restrict free competition.
According to CADE’s technical report, the investigation targets individuals linked to companies including Cargill, ADM do Brasil, Amaggi, COFCO International, NovaAgri, 3 Tentos, and Dual Agroindustrial, as well as representatives from industry associations such as the Brazilian Association of Vegetable Oil Industries (ABIOVE) and the National Association of Grain Exporters (ANEC).
The alleged coordination took place through the Soy Working Group (GTS) — a coalition that manages and enforces the Moratorium. CADE’s analysis describes the GTS as a “highly structured” body with operational and oversight units composed of representatives from competing companies, potentially turning an environmental self-regulation effort into a de facto purchasing cartel.
Evidence cited by the SG includes internal communications and emails exchanged between 2019 and 2024, which discuss producer audits, embargo lists, and sourcing procedures. The data were obtained from a São Paulo court proceeding and shared with CADE for forensic review.
The case now enters the evidentiary phase, allowing the regulator to subpoena documents, collect testimony, and conduct on-site inspections. Violations could fall under Article 36 of Brazil’s Competition Law (12.529/2011), which prohibits agreements that limit or distort competition.
The issue is politically sensitive: the federal government supports the Moratorium, and the CADE tribunal in September decided to keep the pact active until 2025, with preventive antitrust restrictions taking effect on January 1, 2026 — avoiding an abrupt suspension ahead of the COP30 climate summit in Belém.
The outcome will help define how Brazil balances environmental compliance and competitive neutrality — and how accountability extends to executives inside sustainability-driven market agreements.
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