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On July 1, 2026, the Office of Foreign Assets Control (“OFAC”) in the US Treasury Department imposed sanctions on several parties due to links to Brazil-based Primeiro Comando da Capital (i.e., First Capital Command, or “PCC”). This was the first round of sanctions against parties connected to PCC since the US Government’s actions in the spring designating PCC as both a Foreign Terrorist Organization (“FTO”) and a Specially Designated Global Terrorist (“SDGT”). We refer to…

In a context of increasing trade barriers to Brazilian exports, especially the additional tariffs imposed by the United States (US Reciprocal Tariffs) that include Brazilian exports, in addition to environmental restrictions on the export of Brazilian products by the European Union and other countries (such as the Carbon Border Adjustment Mechanism (CBAM) and other carbon control mechanisms (e.g. UK CBAM), imposed by the European Union and other countries), Law No. 15.122/2025 (known as the “Economic Reciprocity Law”)…