🇧🇷Brazil

Multas por Violação de Normas de Proteção ao Consumidor em Pacotes de Viagem

1 verified sources

Definition

In May 2023, Senacon suspended Hurb's (Hotel Urbano) sales of flexible travel packages due to irregularities in business practices and consumer complaints. The company was ordered to present a resolution plan and demonstrate corrected flaws. Failure to comply results in daily fines and additional administrative penalties. The suspension applies to specific product lines, restricting revenue.

Key Findings

  • Financial Impact: R$ 0–[unspecified daily fine amount]; revenue suspension; remediation costs (legal, compliance redesign); reputational loss; potential broader market restrictions.
  • Frequency: Ongoing enforcement; Senacon actively investigates travel companies with high complaint volumes.
  • Root Cause: Lack of transparent cancellation terms, inadequate traveler communication, insufficient proof of consumer consent, manual dispute resolution leading to missed responses, and gaps in contractual duty-of-care language.

Why This Matters

The Pitch: Travel arrangement firms in Brasil face suspension risk when duty-of-care standards (traveler protection, clear cancellation terms, dispute resolution) are not embedded in contracts and tracking systems. Compliance automation—contract transparency audits, automated cancellation processing, and traveler communication logs—prevents Senacon enforcement actions.

Affected Stakeholders

Travel Package Product Managers, Customer Service & Dispute Resolution Teams, Legal/Compliance Officers, Contract Drafters

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Financial Impact

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Methodology & Sources

Data collected via OSINT from regulatory filings, industry audits, and verified case studies.

Evidence Sources:

Related Business Risks

Multas LGPD por Tratamento Inadequado de Dados de Viajantes e Passageiros

Up to 2% of annual Brazilian revenue (max R$ 50,000,000 per violation); daily fines; public disclosure; processing activity bans; litigation costs.

Erros de Cálculo de Comissão - Valor Bruto vs. Líquido

Estimated 2-5% of total commissions processed monthly; for an agency processing R$ 500,000/month in sales at 10% commission (R$ 50,000/month), this represents R$ 1,000–2,500 in monthly leakage or R$ 12,000–30,000 annually.

Atraso no Recebimento de Comissão - Parcelamento de Cliente vs. Pagamento de Fornecedor

Estimated 30–90 day payment lag per installment plan; for an agency with 40% of sales on installment, this represents ~R$ 20,000 in suspended receivables for every R$ 100,000 in monthly sales. Cost of capital (opportunity cost at 6–12% annual interest) = R$ 1,200–2,400 per R$ 100,000 in sales.

Disputas e Reconciliação Não Resolvida de Comissão

Estimated 3–8% of monthly commission disputes resulting in writeoff; for R$ 50,000/month in commissions, this represents R$ 1,500–4,000 in unrecovered disputes annually (R$ 18,000–48,000).

Processamento Manual de Comissão - Falta de Automação

Estimated 40–60 labor hours/month per 5–10 staff agency at effective cost of R$ 50–80/hour = R$ 2,000–4,800/month or R$ 24,000–57,600 annually. Opportunity cost of delayed sales (agents spending time on disputes instead of selling) adds 2–5% to this figure.

Vazamento de Receita por Faturamento Incompleto e Cotações Perdidas

Estimated 2–8% of invoice value lost per client trip (avg. R$ 500–5,000 per invoice → R$ 10–400 loss per transaction); for mid-sized agency (500 annual trips): R$ 50,000–200,000 annually.

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