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a) unification of the free and floating rate markets;b) individuals and corporate entities may purchase and sell foreign currency or make transfers of anynature, without limitation of value, though transfers on behalf of third parties are prohibited;c) Brazilian investment abroad does not depend on authorization and/or any kind of priorcommunication to/from BACEN and is not subject to any limitation of value;d) nonresident individuals or corporate entities in Brazil may maintain accounts in the Country called“nonresident accounts”, with financial institutions authorized to operate in Brazil by BACEN, thoughthe use of such accounts to make transfers on behalf of third parties is, however, forbidden.2. THE BRAZILIAN ANTITRUST ACT (LAW 12,529/2011) AND THE PRE-MERGERREVIEW SYSTEMThe new Brazilian antitrust act (Law 12,529/2011), in force since May 29, 2012, significantly changedthe entire antitrust framework in Brazil, formerly regulated by Law 8,884/94.In fact, the new law introduced the pre-merger review system for the first time in Brazil. Based on thislaw, new regulations were issued.The key change introduced by Law 12,529/2011 is that it consolidated the investigative, prosecutorialand adjudicative functions of the Brazilian authorities into one single agency – the AdministrativeCouncil for Economic Defense (CADE).Today, CADE is composed of: (i) an Administrative Tribunal for Economic Defense, comprised ofsix Commissioners and one President; (ii) a General Superintendence, which took on the formerfunctions of the Secretariat of Economic Law of the Ministry of Justice (SDE/MJ) and the Secretariatfor Economic Monitoring of the Ministry of Finance (SEAE/MF) under Law 8,884/94; and (iii) aDepartment of Economic Studies, responsible for preparing opinions and economic studies, eitheron its own initiative or upon request of the Board of the Administrative Tribunal for Economic Defense,the President of the Administrative Tribunal for Economic Defense, a Reporting Commissioner or theGeneral Superintendent.As stated above, with regard specifically to merger control, Law 12,529/2011 introduced a pre-mergerreview system. If a notifiable transaction is consummated prior to CADE's clearance, the partiesinvolved will be subject to fines ranging from BRL 60 thousand to BRL 60 million. Moreover,administrative proceedings can be initiated and the transaction can be considered void.8