Less than 30 days after the PCC and CV were designated terrorist organizations by the U.S. Government, Brazil already receives the first sanctions, on companies and individuals. No one is off this radar. Is your company already taking action?

When we published, in this same series, that the designation of the PCC and Comando Vermelho would change the Brazilian business environment, a common objection was that the practical effects would take years. They took 26 days.

On July 1, 2026, the U.S. Treasury's Office of Foreign Assets Control, OFAC, announced the inclusion of two Brazilians, three São Paulo companies and one Portuguese company on the SDN blocking list, for ties to the Primeiro Comando da Capital. According to the Treasury itself, it was OFAC's third action against the PCC's structure, but the first after the faction was designated a terrorist organization, and the first to use, against companies linked to the group, the anti-terrorism legal basis of Executive Order 13224. What was a thesis became a precedent. And precedent, in this regime, is the technical name for "it will happen again."

The factWhat exactly happened on July 1

According to the Treasury's official statement, the sanctioned network operated between Florida and São Paulo and allegedly laundered more than 30 million dollars in drug proceeds generated in the United States, using cryptocurrencies to bring the money back to Brazil for the benefit of the PCC. The action was the outcome of an investigation led by a homeland security task force, with the FBI's Miami field office and the money laundering section of the Department of Justice. In January 2026, six members of the Florida branch had already been arrested and indicted in U.S. Federal Court.

Designated, according to the Treasury, were: two Brazilian individuals identified as operators of the São Paulo core; three São Paulo companies in the financial services, payments and construction sectors; and a transport and warehousing company from the Lisbon region, in Portugal, belonging to the same group. The full names appear in the official statement and on the SDN list, both public and cited in the sources at the end. It is worth the note our series always makes: inclusion on the SDN list is an administrative act of the U.S. Executive, based on the allegations and evidence gathered by that government, and not a judicial conviction.

The reachWhy "no one is off this radar" is not a figure of speech

The Treasury's statement devotes an entire section to the implications of the action, and it deserves careful reading by any Brazilian manager. Three points, all taken from the official text:

First, the 50% Rule is already active. Any company owned, directly or indirectly, individually or jointly, 50% or more by the now-blocked persons is also blocked, even if its name does not appear on any list. Discovering this is the responsibility of whoever does business with it, not of the U.S. government.

Second, civil liability does not require intent. OFAC may impose civil penalties for sanctions violations on a strict liability basis. An American company, or an operation that passes through the United States, can be punished even without knowing the counterparty was blocked. That is precisely why banks and business partners cut relationships at the first sign of risk, the de-risking effect that hits innocent third parties.

Third, the statement expressly warns that non-Americans are also within reach. The official text prohibits foreigners from causing or conspiring to cause violations by Americans, and warns that foreign financial institutions facilitating significant transactions for the designated parties may suffer secondary sanctions, losing access to correspondent accounts in the United States. For a Brazilian bank, this is not a regulatory detail, it is an existential risk. And the bank, to protect itself, transfers that demanding standard to every client in its portfolio.

The vacuumThe question almost no one can answer: "so, now what do I do?"

Since the May designation, we have been talking with companies, class associations, firms and public managers. The observation that follows is institutional, the fruit of that experience, and the reader should treat it as the assessment of those who work on the topic, not as a statistic: we have not found, up to the closing of this text, a Brazilian public or private institution with a clear, tested and documented procedure on what to do upon finding evidence of a link between a client, supplier or partner and a designated organization. There is goodwill, there are quality legal alerts, there is growing concern. What there is not is an operational routine: whom to notify, within what deadline, with which documents, preserving which evidence.

This is not a criticism of anyone in particular. The U.S. sanctions regime is a technical world of its own, which until a month ago seemed an exclusive subject for international banks. The designation changed the audience for this subject without asking permission. The problem is that, in this regime, improvisation is costly: reporting wrongly, late or to the wrong agency can turn a victim company into an investigated one.

The pathThe organizational response: a dedicated intelligence unit

The defense that works in this environment is not a stand-alone legal opinion or a one-off check against a list. It is a permanent capability. The most efficient way to build it, in the assessment of INCC and CNC, is to set up an intelligence unit specialized in organized crime and counterterrorism serving the organization itself, even if small, including outsourced. And here comes the warning that runs against the instinct to cut costs: intelligence for combating organized crime and counterterrorism is not a discipline you learn by doing. The unit must be formed, or hired, with professionals of proven experience in these two areas, whoever the provider is. Putting in-house people to learn through their own mistakes is a risk that rarely justifies the savings: in this field, the first mistake can already be the ignored alert, the false positive that brings down a legitimate contract or the report made to the wrong agency. What defines the unit, therefore, is not size, it is function and experience:

• Continuous screening of counterparties: clients, suppliers, partners and ultimate beneficial owners checked against the official sanctions lists, recurrently and not only at onboarding, because lists and ownership structures change all the time.
• Ultimate beneficial owner view and the 50% Rule: the ability to see who is behind each company, adding up the stakes of any sanctioned parties, which is where the invisible risk lives.
• Written response protocol: the step-by-step of what to do when facing an alert, with responsible parties, deadlines and channels defined before the crisis, including the guide for communicating with authorities we detail in the next section.
• Evidence preservation: organized keeping of contracts, payment instructions, invoices, bills of lading and check records, which are exactly the documents the official agencies request.
• Interface with legal, compliance and authorities: the unit does not replace the attorney or the compliance officer; it feeds both with structured information and maintains the channel with public agencies.

None of this requires a large structure, and the screening and initial diagnosis can be done with free public tools, including those INCC itself provides, described below. What is not advisable to skimp on is the experience of whoever does the analysis: the tool finds the name, but it is the analyst with real experience in organized crime and counterterrorism who recognizes the pattern, reads the context and knows what to do with the finding.

The protocolI found evidence. Now what? The official step-by-step guide

Everything that follows was taken from official sources of the U.S. and Brazilian governments, cited at the end. There is no inference of ours in the deadlines, channels and documents listed. The overall design is this:

In the United States: the four official channels

In Brazil: the two channels the company needs to know

The timeWhy the urgency, this time, is not alarmism

Three reasons, all factual. First: the pace. Between the FTO designation taking effect and the first sanctions, 26 days passed, and the Treasury has been announcing actions against Latin American criminal networks in sequence, week after week. Second: the method. The July 1 statement describes ongoing investigations, arrests already made and permanent coordination between the FBI, the Department of Justice and the Treasury, which indicates a pipeline, not an isolated event. Third: the asymmetry. Getting on the list is immediate and without notice; getting off, through OFAC's own reconsideration procedure, is slow and discretionary. Whoever prepares after the problem does not prepare, they manage a loss.

The minimum move any company can make this week costs zero: measure its own exposure, check its counterparties against the official lists, write a one-page response protocol and define who answers for this subject. The complete move, the specialized intelligence unit, formed or hired with people of proven experience in the field, is the natural evolution of that first step.