On July 1, 2026, the U.S. Department of the Treasury’s Office of Foreign Assets Control (“OFAC”) imposed sanctions on three Brazilian companies, two Brazilian individuals, and one Portuguese company for their ties to Primeiro Comando da Capital (“PCC”).
According to OFAC, the sanctioned Brazilian criminal network exploited the U.S. financial system to launder money stemmed from drug trafficking and operated primarily out of Florida and São Paulo. OFAC found that the network laundered more than USD 30 million and used cryptocurrency to transfer the funds to Brazil for the benefit of the criminal organization. According to OFAC, the sanctioned companies formed a network used by the sanctioned Brazilian individuals to conceal and launder the proceeds of their illicit activities.
The sanctions result in the blocking of all property and interests in property of the sanctioned individuals and entities that are within U.S. jurisdiction, as well as any entity owned 50% or more by them. In addition, the measures carry significant implications for other companies engaging in transactions with the sanctioned parties, including the risk of secondary sanctions and restrictions on access to the U.S. financial system.
Considering the recent U.S. designation of Brazilian criminal organizations, including the PCC, as Foreign Terrorist Organizations (“FTOs”), these sanctions show that the designation is now being followed by concrete enforcement, and they reinforce the growing scrutiny of individuals, companies, and financial structures that may be directly or indirectly linked to organized crime in Brazil. We have examined these developments in two earlier publications: the U.S. designation of Brazilian criminal organizations as FTOs and its regulatory and compliance impact on companies operating in Brazil, and the global enforcement and compliance implications of their designation as transnational criminal organizations (TCOs).
The action highlights the importance of implementing effective sanctions screening procedures, identifying ultimate beneficial owners (“UBOs”), and monitoring transactions that may have direct or indirect connections to Brazilian criminal organizations.
In this context, companies should assess whether their third-party due diligence and ongoing monitoring procedures are sufficiently robust to identify risks related to sanctions, ultimate beneficial ownership, complex corporate structures, and potential direct or indirect ties to transnational criminal organizations. The effectiveness of these controls is essential to mitigating regulatory, financial, and reputational risks and remains a fundamental pillar of a robust compliance program. For more information and to discuss how these developments may affect your company, please contact our team.