Brazil

On May 28, 2026, Secretary of State Marco Rubio announced that the United States Department of State (DOS) designated Brazil-based drug-trafficking and transnational criminal organizations Comando Vermelho (CV) and Primeiro Comando da Capital (PCC) as Specially Designated Global Terrorists (SDGTs) under Executive Order (EO) 13224, as amended by EO 138861, which targets terrorism financing. The DOS also announced its intention to designate CV and PCC as Foreign Terrorist Organizations (FTO), effective June 5, 2026, pursuant to Section 219 of the Immigration and Nationality Act and EO 13224. These designations carry significant compliance implications for companies and business units with a US nexus, non-US companies that continue to do business with CV and PCC, and individuals and entities with business operations, counterparties, supply chains, or investment relationships in Brazil. Background CV (based in Rio de Janeiro) and PCC (based in São Paulo) are among the most prominent criminal organizations in Brazil. According to the DOS, together they command thousands of members and have orchestrated attacks against Brazilian police officers, public officials, and civilians. They operate throughout Brazil, and their networks extend across the Western Hemisphere into the US, with transactions also reaching Africa and Europe. Public reporting indicates that, within Brazil, CV and PCC have infiltrated or exploited legitimate sectors of the economy – including fuel distribution and retail, public transportation, financial services and fintech, real estate, and other local service industries – while extorting businesses and disrupting hiring and logistics in areas under their influence. Reporting also suggests that organized crime, including CV and PCC, has in some jurisdictions infiltrated politics, public contracting, and local power structures. These designations align with a broader pattern of heightened US enforcement activity involving transnational criminal organizations in Latin America. On January 21, 2025, President Donald Trump issued EO 14157, directing the “total elimination” of certain Latin American drug cartels and transnational criminal organizations. The following month, the Administration designated eight Mexican and Colombian cartels – including the Sinaloa Cartel, CJNG, and Tren de Aragua – as both FTOs and SDGTs, as discussed in our prior alert. Since then, the Administration has continued to expand the scope of these designations through successive US Department of the Treasury (Treasury) and DOS actions aimed at cartel-linked networks across sectors and activities including oil and gas, timeshare fraud, real estate, and agriculture, alongside related criminal prosecutions by the US Department of Justice (DOJ) and coordination with the Mexican government. Criminal, civil and regulatory enforcement These designations may present significant legal and compliance implications for industries with operational, financial, or supply-chain touchpoints in the Americas, including agriculture, chemicals and pharmaceuticals, financial services, construction, logistics, transportation and shipping, energy, oil and gas, mining and natural resources. Industries that are cash‑intensive, embedded in local supply chains, or historically exposed to cartel activity may face heightened scrutiny. The financial services sector may face particular risk, as banks, fintech companies, and money‑services businesses have historically been subject to regulatory and law enforcement scrutiny for facilitating transactions – whether inadvertently or willfully – linked to SDGTs and FTOs. Tourism and hospitality, as well as retail and consumer goods sectors, have also been impacted by US-led sanctions enforcement. Regulatory exposure. Treasury’s Office of Foreign Assets Control (OFAC) routinely applies a strict liability standard in civil enforcement actions, meaning that companies and individuals may be held liable for sanctions violations regardless of knowledge. The maximum civil monetary penalty for violations of most OFAC-administered sanctions programs is USD377,700 per transaction, or twice the value of the underlying transaction, whichever is greater. Effective immediately under the SDGT designations, all property and interests in property of CV and PCC that are in the US or in the possession or control of US persons are blocked (i.e., transferring or otherwise dealing with the property is prohibited). This applies to tangible and intangible assets, whether present, future, or contingent. Under OFAC’s 50 Percent Rule, any entity owned 50 percent or more, in the aggregate, by one or more blocked persons is also considered blocked. US persons are generally prohibited from engaging in transactions or dealings with blocked persons or their property without a license or other authorization from OFAC. Companies may wish to ensure they have appropriate controls in place to comply with regulatory requirements related to blocking or freezing funds involving CV and PCC. Criminal penalties for willful violations. Willful violations of the International Emergency Economic Powers Act (IEEPA), on which both EOs are based, are subject to penalties of up to 20 years’ imprisonment and a USD1,000,000 fine. The US has also charged sanctions violators with related offenses including conspiracy, aiding and abetting, and money laundering. Criminal penalties for material support of terrorism. Under 18 U.S.C. § 2339B, knowingly providing – or knowingly attempting or conspiring to provide – material support or resources to an FTO is a criminal offense punishable by up to 20 years’ imprisonment. Material support may include financial services (e.g., services relating to currency, monetary instruments, or financial securities), as well as lodging, training, and transportation. The facilitation of payments, directly or indirectly, can constitute “material support” and give rise to criminal liability. US authorities also assert extraterritorial jurisdiction over material support offenses, including where support occurs outside the US but involves US dollar-denominated transactions, routing through US financial systems, or communications transmitted via US servers. Civil liability. The Anti-Terrorism Act (ATA) and Justice Against Sponsors of Terrorism Act (JASTA) provide a private right of action for US nationals injured by acts of international terrorism to sue for damages based on an aiding and abetting theory (i.e., that the defendant knowingly provided substantial assistance to an FTO or SDGT). ATA and JASTA litigation in the US have increased markedly in the last several years, including with respect to financial institutions, cryptocurrency exchanges, social media companies, medical supply and manufacturing companies, and others whose goods and/or services have allegedly been used by SDGTs or FTOs in furtherance of terrorist acts. Accordingly, companies that engage with CV or PCC at any point in the supply chain may face civil litigation risk. Seizure and forfeiture. US seizure and forfeiture authorities in the sanctions context derive from national security statutes, general federal forfeiture statutes (e.g., 18 U.S.C. § 983 and Title 19 customs authorities), and DOJ procedures for federal seizure of property linked to unlawful conduct. The US often pursues civil or criminal forfeiture under separate statutory authorities where sanctioned activity is tied to underlying offenses such as terrorism, evasion, or money laundering, enabling title to the seized property to vest in the US. In civil cases, the DOJ has pursued forfeiture actions against assets – both in the US and abroad – deemed traceable to illicit conduct, without requiring criminal conviction. In such cases, agencies may leverage judicial or administrative processes under federal forfeiture law to seize property and seek forfeiture through court proceedings. In criminal sanctions cases, forfeiture may be imposed as part of sentencing following prosecution for willful violations, often alongside fines and imprisonment, and typically coordinated between OFAC (civil enforcement) and DOJ (criminal enforcement). Secondary sanctions. Under US counterterrorism and counter-terrorist financing sanctions authorities (including EO 13224), the US can designate non‑US persons for engaging in specified dealings with sanctioned individuals or entities, including where there is no US nexus (i.e., no US dollar, person, or territory involved). Immigration consequences. Members and representatives of designated FTOs are prohibited from entering the US, and individuals who provide material support to FTOs may be deemed inadmissible or subject to removal. Compliance implications for companies with Brazil exposure Given CV and PCC's reported involvement in legitimate industries and geographic presence in certain areas in Brazil, these designations may present compliance challenges that extend beyond traditional sanctions screening. Companies are encouraged to assess the following areas. Targeted risk assessments Companies should consider assessing existing compliance programs and controls to ensure that they are adequately tailored to the risks arising from cartel activity and any links to CV and PCC. In particular, companies should consider conducting such assessments to help identify and mitigate risks of possible touchpoints with cartels, including in third party relationships. In certain sectors, this might involve enhancing risk-based programs designed to prevent money laundering and the financing of terrorism – including know your customer (KYC) and due diligence measures – to ensure they are adequately tailored to industries and geographies in Brazil where CV or PCC operate and adapted to specific higher-risk products or services. “Lookback” reviews of historical counterparty relationships may be warranted to refresh risk ratings. Regulators also increasingly expect that, where warranted, compliance programs will perform more holistic supply chain KYC that does not end at one’s immediate customer or counterparty, but instead involves “KYCC,” i.e., knowing one’s customer’s customers and/or one’s counterparty’s counterparties. Sanctions screening Companies should consider assessing whether their screening procedures incorporate CV, PCC, and all known aliases, and consider re-screening existing customers, contractors, and counterparties. Under the 50 Percent Rule, entities owned 50 percent or more by blocked persons are also blocked – even if not individually designated. Transaction monitoring Monitoring systems should be calibrated to detect red flags associated with CV and PCC activity, including unusual pricing in high-risk regions, atypical payment routing, and supply-chain touchpoints in areas of known territorial control. Supply chain and correspondent banking Companies with indirect exposure through suppliers or distribution networks in high-risk regions may face increased scrutiny with respect to third-party monitoring. Foreign financial institutions maintaining US correspondent accounts may also face exposure under secondary sanctions frameworks – including the risk of being cut off from the US financial system – as well as potential designation by the US Treasury’s Financial Crimes Enforcement Network (FinCEN) as primary money laundering concerns under Section 311 of the USA PATRIOT Act for processing transactions involving designated persons or affiliates. Looking ahead Enforcement patterns following the Mexican cartel designations – including successive OFAC actions, FinCEN alerts, and DOJ prosecutions – may signal the potential for additional designations of CV- and PCC-linked individuals and entities. Adaptable and comprehensive compliance programs are likely to continue to play a key role for companies operating in this evolving enforcement landscape. Conclusion The designation of CV and PCC as SDGTs, with FTO designations to follow, represents an expansion of the Trump Administration’s counterterrorism enforcement activity into Brazil. These actions do not create new obligations under Brazilian law, but they create potential exposure under US law for entities with a US nexus. Prior enforcement activity involving similar designations provides insight into related regulatory, civil, and criminal enforcement activities that may follow. As the SDGT blocking obligations are already in effect, companies are encouraged to assess their exposure and ensure that compliance programs are aligned with these recent developments. DLA Piper’s cross-border team supports companies in assessing and addressing compliance considerations associated with these developments. For further information and assistance, please contact the authors.

Move reinforces the firm’s strategic focus on wealth and succession planning, with a strong private client offering São Paulo, March 31, 2026 – Madrona Advogados announces the appointment of João Guizardi as a new partner, reflecting his track record and contributions to the growth of the firm’s Wealth Planning practice and expanding the firm’s capabilities in complex wealth, succession, and high-end family law matters.   With solid experience in civil law, with a focus on family and succession matters, João Guizardi has led Madrona Advogados’ Wealth Planning practice for the past three years, combining technical sophistication, strategic insight, and a thoughtful approach to matters that are critical to individuals, entrepreneurial families, and family offices. His practice is focused on designing legal structures aimed at protecting assets, mitigating risk, preventing disputes, and preserving legacy.   The practice has been recognized by leading national and international legal rankings, including Chambers High Net Worth, Leaders League, Análise Advocacia, and the Brazil’s Leading Lawyers Awards.   Throughout his career, Guizardi has advised on strategic projects involving wealth and succession structuring, as well as led complex disputes and sensitive matters, including probate proceedings, divorces, changes to marital property regimes, and family-related conflicts. He also has experience in wealth and corporate reorganizations, negotiation of family and shareholder arrangements, and the drafting of planning instruments, including wills, prenuptial and postnuptial agreements, stable union agreements, and advance directives.   “João’s work is defined by technical excellence and the ability to handle highly sensitive matters with care, strategy, and genuine empathy for clients’ needs. His promotion to partner recognizes his trajectory and reinforces our commitment to further expanding our Wealth Planning practice, which has become increasingly relevant to our clients,” said Danilo Mininel, CEO of Madrona Advogados.   “Becoming a partner is an opportunity to continue supporting our clients and their families in building safe, sophisticated, and tailored legal solutions focused on preserving wealth, mitigating risk, and navigating sensitive decisions,” said João Guizardi.   Guizardi holds a postgraduate degree in Wealth and Succession Planning from Fundação Getulio Vargas (FGV) and a postgraduate degree in Civil Procedure from the Pontifical Catholic University of São Paulo (PUC-SP). He holds an LL.B. from Toledo Prudente Centro Universitário and is a member of the Family and Succession Law Committee of the Brazilian Institute of Wealth Planning (IBRAPP). With this appointment, Madrona Advogados further strengthens its Wealth Planning practice and expands its capacity to advise clients on complex wealth and succession matters, reaffirming its commitment to technical excellence, strategic vision, and value creation.   About Madrona Advogados Madrona Advogados is a full-service firm that combines technical excellence with a pragmatic, seamless approach to delivering precise solutions for complex matters. The firm has 49 partners and approximately 400 professionals across a wide range of legal practices and administrative functions. Recently, the firm announced a partnership with Coelho & Dalle, with offices in Recife, Fortaleza, and São Paulo, expanding Madrona’s presence in these locations. Madrona also welcomed Roberto Salles as a partner to strengthen its tax practice. According to TTR Brasil’s 2025 annual report, the firm is among the 10 most active practices in mergers and acquisitions (M&A). Madrona also has strong national recognition in areas such as Capital Markets, Public Law and Infrastructure, Civil Litigation and Arbitration, Tax, and several other practices within its nationwide full-service positioning. In recent years, the firm has been recognized by legal publications and directories including Chambers Brazil (Elite in M&A), Chambers Global, The Legal 500, LL250, LACCA Approved, Leaders League, IFLR1000, Who’s Who Legal, Análise Advocacia 500, Análise Advocacia, and Análise Mulher.

Luis Felipe Baptista Luz transitions from executive leadership to Chairman of the Board; transition to be completed in July b/luz has announced a change in its executive leadership. Effective July 1, 2026, Fernando Bousso will assume the role of Chief Executive Officer, while Luis Felipe Baptista Luz will transition to Chairman of the Board. The transition will begin to be communicated to the market on March 31 and will take place over the coming months, with completion expected in July. According to the firm, the process has been carefully structured to ensure operational continuity and strategic alignment throughout the transition. This succession marks a new chapter for b/luz, which has been led by Luis Felipe for more than two decades. The change also reflects an advancement in the firm’s governance structure. With a well-established track record within the firm, Fernando Bousso steps into the role with responsibility for leading operations and guiding the next phase of growth. “I take on the role of CEO with a strong sense of responsibility and commitment to the continuity of the project built over more than two decades. Our focus is to build on this foundation and lead the next cycle of development with consistency and a long-term perspective,” said Bousso. Under the new structure, Luis Felipe Baptista Luz will take on a more strategic role, contributing to institutional decisions and the firm’s long-term direction. “b/luz is evolving institutionally to support its next phase of development, with an even stronger governance structure,” said the founder. Founded more than 20 years ago, b/luz positions itself as a firm that integrates legal expertise, business insight, and the use of technology and data, serving companies operating in complex regulatory environments. According to the firm, the transition does not change its operating model or client relationships, maintaining a focus on technical excellence, close client engagement, and a strategic approach. The new structure reinforces b/luz’s positioning as an organization driven by governance and long-term planning, in a context of increasing regulatory complexity and business transformation. “We are entering a new cycle, committed to advancing b/luz while maintaining the consistency of what has been built so far and expanding our ability to anticipate market transformations,” added Fernando Bousso. b/luz anuncia Fernando Bousso como novo CEO  Luis Felipe Baptista Luz deixa a liderança executiva e assume a presidência do conselho; mudança será concluída em julho O escritório b/luz anunciou uma mudança em sua liderança executiva. A partir de 1º de julho de 2026, Fernando Bousso assume oficialmente como CEO, enquanto o, Luis Felipe Baptista Luz, passa a atuar como presidente do conselho. A transição começa a ser comunicada ao mercado em 31 de março e será conduzida ao longo dos próximos meses, com conclusão prevista para julho. Segundo o escritório, o processo foi estruturado para garantir continuidade na operação e alinhamento estratégico durante a mudança. A sucessão marca um novo momento para o b/luz, que por mais de duas décadas teve Luis Felipe à frente da liderança executiva. A reorganização também representa um avanço na estrutura de governança da banca. Com trajetória consolidada dentro do escritório, Fernando Bousso assume o comando com a responsabilidade de liderar a operação e conduzir o próximo ciclo de crescimento. “Assumo a posição de CEO com senso de responsabilidade e compromisso com a continuidade do projeto construído ao longo de mais de duas décadas. Nosso foco é dar sequência a esse trabalho e conduzir o próximo ciclo de desenvolvimento com consistência e visão de longo prazo”, afirma Bousso. Na nova estrutura, Luis Felipe Baptista Luz passa a atuar de forma mais estratégica, participando das decisões institucionais e do direcionamento de longo prazo do escritório. “O b/luz evolui institucionalmente para sustentar seu próximo ciclo de desenvolvimento, com uma estrutura de governança ainda mais sólida”, diz o fundador. Fundado há mais de 20 anos, o b/luz se posiciona como um escritório que integra prática jurídica, visão empresarial e uso de tecnologia e dados, atendendo empresas em contextos regulatórios complexos. De acordo com o escritório, a mudança não altera o modelo de atuação nem o relacionamento com clientes, mantendo o foco em excelência técnica, proximidade e abordagem estratégica. A nova configuração reforça o posicionamento do b/luz como uma organização orientada por governança e planejamento de longo prazo, em um cenário de crescente complexidade regulatória e transformação dos negócios. “Entramos em um novo ciclo, com o compromisso de evoluir o b/luz mantendo a consistência do projeto construído até aqui e ampliando nossa capacidade de antecipar as transformações do mercado”, afirma Fernando Bousso.

Oceana Metals Limited (ASX: OCN) ("Oceana") entered into a binding agreement with private vendors to acquire 100% of the shares in the private company ("Target") which is the holder of the mineral rights comprised by the Serra Negra rare earths and niobium Project in Minas Gerais State, Brazil (the "Acquisition"). Under the Acquisition, Oceana will pay total upfront and deferred consideration of up to US$10.3 million, comprising: (a) US$2.95 million in cash and 20,000,000 fully paid ordinary shares in Oceana (approximately US$5.0 million at a deemed issue price of A$0.36 per share) on completion; and (b) deferred Milestone Payments of up to US$2.25 million (US$750,000 upon announcing an initial JORC mineral resource, and US$1.5 million upon announcing a JORC resource of at least 100Mt at 4% TREO or equivalent). The vendors will also be granted a 2.5% net smelter royalty on all payable commodities extracted from the permits (excluding iron ore). Completion of the Acquisition remains subject to customary conditions precedent. Veirano Advogados acted as Brazilian legal counsel to Oceana Metals on the Acquisition, providing advice on all aspects of the transaction from a Brazilian law perspective, including structuring the Transaction, reviewing corporate and regulatory requirements, and coordinating with foreign counsel to ensure an efficient and integrated cross-border signing. Hamilton Locke acted as Australian legal counsel on the Acquisition.