The New FTO Risks to Businesses in Brazil
Companies face significant compliance challenges with the unprecedented U.S. designation.
To appreciate the significance of the U.S. designation of two Brazilian criminal organizations—Comando Vermelho and Primeiro Comando da Capital—as Foreign Terrorist Organizations (FTOs), effective June 5, one need only consider Brazil’s most iconic city: Rio de Janeiro. Comando Vermelho (CV) is said to control much of the cidade maravilhosa. Like so many other Latin American criminal organizations, CV is heavily involved in drug trafficking and uses violence, kidnapping, and extortion to maintain power. But in certain parts of Rio and beyond, CV goes further, performing a...
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