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Countries › Paraguay › Guide › 13. Regulation › Anti corruption in Paraguay: domestic and foreign bribery, influence peddling, private bribery and individual liability

Anti corruption in Paraguay: domestic and foreign bribery, influence peddling, private bribery and individual liability

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Last verified: 2026-10-28 · Status: Stable

Bribing a Paraguayan official is a crime of up to 2 years or a fine for discretionary acts and up to 3 years for acts in breach of duty, with up to 5 years for bribing judges or arbitrators; since 2019 bribing foreign and international officials is punished too. Influence peddling (up to 3 years, 5 when aimed at judges or prosecutors) and, since 2019, commercial bribery between companies (up to 2 years, 3 if aggravated) are also crimes, and all of them are predicates for money laundering. Paraguayan criminal law punishes individuals: managers and representatives answer personally, and the foreign bribery law contains no corporate liability article, so compliance programmes earn no statutory fine reduction.

USD figures use PYG 5,868.31 per US dollar, the Banco Central del Paraguay reference quotation for 28 October 2026. Amounts set in minimum wages use the monthly minimum wage of PYG 3,044,000 and the daily minimum wage (jornal) of PYG 117,077 in force since 1 July 2026 under Resolución MTESS 670/2026. Conversions are for orientation only and move with each wage adjustment.

Key facts

Bribery of a domestic official in breach of duty (briber), maximum prison3 yearsCódigo Penal art. 303, as of 2026-10-28 · in force
Foreign bribery (briber), maximum prison5 yearsLey 6430/2019 art. 3, as of 2026-10-28 · in force
Foreign bribery offence enacted2019-11-18 dateLey 6430/2019, as of 2026-10-28 · in force
Corporate criminal liability for briberyNo article in Ley 6430/2019; individuals acting for companies are liable (Penal Code art. 16) Ley 6430/2019; Código Penal art. 16, as of 2026-10-28 · in force
Private sector bribery criminalisedYes, up to 2 years (3 aggravated) Código Penal art. 268b and 268c (Ley 6452/2019), as of 2026-10-28 · in force
Facilitation payment exceptionNone in the Penal Code Código Penal art. 302, as of 2026-10-28 · in force
Influence peddling, maximum prison3 (5 when aimed at judges or prosecutors) yearsLey 2523/2004 art. 7, as of 2026-10-28 · in force

The rule

1. Bribing domestic officials. Offering, promising or guaranteeing a benefit to an official in exchange for a past or future official act that depends on the official's discretion is punished with up to 2 years in prison or a fine; for an act that breaches the official's duties, up to 3 years (attempt is punishable). Offering a benefit to a judge or arbitrator for a judicial act or decision is punished with up to 3 years or a fine, and with 1 to 5 years if the act breaches judicial duties. Officials who solicit or accept are punished with up to 3 years or a fine, up to 5 years for breach of duty; judges and arbitrators up to 5 and 10 years respectively. Omitting an act counts as an act, and a payment to an arbitrator without the other party's knowledge counts as a benefit.
Cost to do it: Criminal exposure; no fee.
Example: A logistics manager who offers PYG 20,000,000 to a municipal inspector to approve a warehouse permit in breach of zoning rules commits soborno agravado (art. 303), up to 3 years. / A US$5,000 'facilitation payment' to speed up a discretionary licence is soborno under art. 302; the Penal Code has no facilitation payment exception.Ley Nº 1160/1997, Código Penal, Art. 300, 301, 302, 303 and 304, 1997-11-26 official text · verified 2026-10-28
2. Foreign bribery. Since November 2019, promising or guaranteeing a benefit to a foreign public official or an official of an international organisation, for that person or a third party, in exchange for a discretionary act is punished with up to 2 years or a fine, and up to 5 years when the act breaches the official's duties. Offering benefits to obtain votes, laws or regulations, or the award or continuation of contracts in international business, or judicial acts of foreign judges, prosecutors or arbitrators, is also punished. Foreign officials who solicit or accept such benefits face up to 3 years, or 5 years for judges, prosecutors and arbitrators.
Cost to do it: Criminal exposure; no fee.
Example: A Paraguayan exporter's manager who promises a commission to a customs official in a neighbouring country to clear a shipment commits soborno transnacional. / A US$50,000 success fee to an official of an international body to win a contract is punished under art. 3 whatever the size of the deal.Ley Nº 6430/2019, Previene, tipifica y sanciona los hechos punibles de cohecho transnacional y soborno transnacional, Art. 2, 3 and 4, 2019-11-18 official text · verified 2026-10-28
3. Influence peddling and post employment rules. Receiving or being promised money or another benefit, for oneself or a third party, to mediate before an official in a matter they handle, invoking real or simulated influence, is punished with up to 3 years or a fine, and the same applies to whoever gives or promises the benefit to obtain an official's favour; when the influence is aimed at judges or prosecutors the maximum rises to 5 years. Former officials who, within 1 year after a public contract was signed with their entity, take a job with or a stake in the favoured company are punished with 100 to 360 day fines, and offenders can be barred from public office for 1 to 10 years. Illicit enrichment by officials carries 1 to 10 years.
Cost to do it: Fines in day fines; see the fine rule below.
Example: A consultant paid a PYG 100,000,000 'success fee' to obtain a ministry's approval by invoking ties to the minister commits tráfico de influencias, as does the company that pays. / Hiring the procurement official who awarded you a contract within a year of signing exposes that official to 100 to 360 day fines (art. 4).Ley Nº 2523/2004, Previene, tipifica y sanciona el enriquecimiento ilícito en la función pública y el tráfico de influencias, Art. 3, 4, 5 and 7, 2004-12-13 official text · verified 2026-10-28
4. Private (commercial) bribery. Since December 2019 the Penal Code punishes, as offences against competition, a manager or representative of any company or organisation who solicits or accepts a benefit in trade in exchange for accepting another's offer on terms disadvantageous to competitors (cohecho privado), and whoever offers, promises or guarantees such a benefit to obtain a competitive advantage (soborno privado). Each is punished with up to 2 years or a fine, rising to up to 3 years for large benefits or professional or gang conduct.
Cost to do it: Criminal exposure; no fee.
Example: A supplier that gives a supermarket buyer a car to win shelf space over competitors commits soborno privado; the buyer commits cohecho privado. / A kickback of US$100,000 to a mining company's procurement manager is a large benefit and can carry up to 3 years.Ley Nº 1160/1997, Código Penal, art. 268b and 268c added by Ley Nº 6452/2019, Art. 268b and 268c, 2019-11-29 official text · verified 2026-10-28 · changed: Ley Nº 6452 (promulgated 29 November 2019, published 2 December 2019) added art. 268b and 268c in a new chapter on offences against competition.
5. Who is liable and the fine unit. Paraguayan criminal liability is personal: whoever acts as representative or organ member of a company, partner with powers, legal representative, or manager or person expressly put in charge of the company's duties answers personally for the offence, even if the personal qualities required by the offence exist only in the company. Ley 6430/2019 contains no article on corporate liability. Criminal fines are in day fines: 5 to 360 day fines unless the law says otherwise, each worth at least 20 percent and at most 510 daily minimum wages, set by the court on the offender's net daily income; courts can add a complementary fine where the offender obtained or sought to obtain enrichment.
Cost to do it: Day fine range at the July 2026 jornal: PYG 23,415 to PYG 59,709,270 per day fine; the theoretical maximum of 360 day fines is PYG 21,495,337,200 (about US$3,662,952).
Example: A general manager who signs off a bribe answers personally even though the contract benefited only the company (art. 16). / The most a court can fine an individual for a 360 day fine offence is about US$3,662,952 at the current wage, before any confiscation.Ley Nº 1160/1997, Código Penal, Art. 16, 52 and 53, 1997-11-26 official text · verified 2026-10-28
6. Money laundering link and confiscation. Domestic bribery (Penal Code art. 300 to 303), influence peddling and illicit enrichment (Ley 2523/2004), private bribery (art. 268b and 268c) and transnational bribery are listed predicate offences for money laundering, so handling bribe proceeds exposes managers and banks to a separate offence of up to 5 years, 10 if commercial. Since 2019 courts can order confiscation of substitute value when the proceeds themselves cannot be confiscated.
Cost to do it: Confiscation of the value obtained.
Example: If a bribe paid to win a PYG 5,000,000,000 public contract cannot be traced, the court can order payment of an equivalent sum (art. 91). / Banks and other obligated subjects must report suspicious payments linked to bribery to SEPRELAD; see the AML page.Ley Nº 1160/1997, Código Penal, art. 91 and 196 as amended by Ley Nº 6452/2019, Art. 91 and 196 num. 1, 2019-11-29 official text · verified 2026-10-28
ConductNormMaximum
Benefit to a domestic official for a discretionary actCódigo Penal art. 3022 years or fine
Benefit to a domestic official for an act in breach of dutyCódigo Penal art. 3033 years
Benefit to a judge or arbitratorCódigo Penal art. 302 and 3033 years or fine; 1 to 5 years in breach of duty
Benefit to a foreign or international officialLey 6430/2019 art. 32 years or fine; 5 years in breach of duty
Paying for influence over an officialLey 2523/2004 art. 73 years or fine; 5 if aimed at judges or prosecutors
Commercial bribery of a company's managerCódigo Penal art. 268c2 years or fine; 3 if aggravated

Bribery offences and maximum prison terms for the briber

Worked example

  • A foreign contractor's country manager agrees to pay a 5 percent commission through a local agent to a ministry official to win a road maintenance contract. The manager and the agent face prosecution for soborno agravado (up to 3 years), the official for cohecho pasivo agravado (up to 5 years), and handling the commission is a laundering predicate (up to 5 years, 10 if commercial). The contractor company itself is not prosecuted as such, but its representatives answer personally (Penal Code art. 16).
  • The same contractor's regional office bribes an official in a neighbouring country to win a tender there; Paraguayan prosecutors can pursue the Paraguayan managers under Ley 6430/2019, with up to 5 years if the act breached the official's duties.

Step by step

  1. Adopt a written anti bribery policy that bans payments to domestic and foreign officials, facilitation payments and commercial kickbacks.
  2. Run due diligence on agents, customs brokers and intermediaries, with audit rights and anti bribery clauses in their contracts.
  3. Record gifts, hospitality and donations to officials and political actors, and route approvals through compliance.
  4. Screen hires of former officials against the 1 year post contract rule in Ley 2523/2004 art. 4.
  5. Train managers on personal liability under Penal Code art. 16 and report suspicious payments internally and, for obligated subjects, to SEPRELAD.

Common traps

  • Promises are enough: the offence is complete when a benefit is offered, promised or guaranteed, not only when paid.
  • There is no facilitation payment exception; small payments for routine discretionary acts are soborno under art. 302.
  • Commercial bribery between companies has been a crime since December 2019, which many compliance programmes still overlook.
  • Without corporate criminal liability, enforcement focuses on the individuals who sign or approve payments, including expatriate managers.
  • Bribery proceeds are laundering predicates, so banks may freeze or report flows linked to suspect contracts.

Sources

Related pages

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