U.S. Terrorist Designations of Brazilian Crime Groups

On May 28, 2026, the U.S. State Department designated the Primeiro Comando da Capital (PCC) and Comando Vermelho, two of Brazil’s largest criminal organizations, as Specially Designated Global Terrorists (SDGTs) and announced its intention to designate both groups as Foreign Terrorist Organizations (FTO) effective June 5, 2026.[1] This long-anticipated action, which we analyzed in our previous post, represents a critical milestone in the U.S. government’s continuing and expanded effort to target Latin American transnational organized crime using counterterrorism authorities. The new designation fits squarely within the Trump administration’s strategy of deploying counterterrorism tools against Latin American criminal organizations, following similar designations in Mexico and Colombia.

For multinational companies operating in Brazil, these designations of the PCC and Comando Vermelho significantly expand potential criminal liability under U.S. antiterrorism statutes that prohibit providing material support to FTOs. The Anti-Terrorism Act, as amended by the Justice Against Sponsors of Terrorism Act, also exposes companies to civil suits in U.S. federal courts for treble damages where plaintiffs allege that companies have aided and abetted and/or conspired with groups that have been designated as FTOs. Even companies without a direct U.S. presence may face suit under the Anti-Terrorism Act, as U.S. courts have asserted jurisdiction over foreign entities if the alleged conduct is sufficiently connected to the United States. Companies with operations, supply chains, or local vendor relationships in Brazil should be vigilant in evaluating and managing exposure in regions where these groups exercise territorial control. Specifically, enhanced due diligence and risk assessments, strong internal compliance controls, and vigilant financial and operational monitoring are key steps companies should consider taking to avoid entanglement with FTOs.