Criminal groups, terrorist designations and business risk: lessons from Brazil

What changes for businesses when organised crime groups are designated as terrorist organisations? What should legal and compliance teams do to assess and manage their exposure?

The International Academy of Financial Crime Litigators and the Basel Institute on Governance invite you to a closed-door online knowledge exchange on the implications of US terrorist designations for businesses operating in Latin America. Drawing on Brazil and other jurisdictions, speakers will examine the legal risks and practical considerations for risk assessments, due diligence and escalation processes.

Who should attend

The session is intended for Academy Fellows and invited practitioners, particularly lawyers and legal, compliance and anti-money laundering professionals at multinationals and financial institutions operating in Brazil and other Latin American countries affected by organised crime.

To support a focused and candid exchange, participation is by invitation or subject to approval by the organisers. The session will be held under the Chatham House Rule: participants may use the information shared but may not reveal the identity or affiliation of speakers or other participants.

Speakers

• Isadora Fingermann, White Collar Partner, TozziniFreire Advogados
• Prof. Vladimir Aras, Federal Appellate Prosecutor and University Professor, Brazil
• Adam S. Kaufmann, Executive Partner, Lewis Baach Kaufmann Middlemiss
• Diego Sierra, Co-Head of Arbitration and Litigation, Von Wobeser y Sierra
• Dr Maria Nizzero, Principal, Head of Sanctions, UK Finance (moderator)
• Elizabeth Ortega, Academy Co-Founder and Founder, ECO Strategic Communications (opening remarks)

Background reading

The Designation of Brazilian Criminal Organizations as Foreign Terrorist Organizations (FTOs) by the U.S. Government: Legal Consequences in Brazil, by Isadora Fingermann in the Spring 2026 edition of the Academy Bulletin. Download the PDF.

More information

Since early 2025, the United States has changed how it uses terrorism designations. Foreign Terrorist Organization (FTO) status has historically been associated with politically and ideologically motivated groups. Following Executive Order 14157, it has been applied to drug cartels and transnational criminal organisations, beginning with several Latin American organisations and including Brazil’s Primeiro Comando da Capital (PCC) and Comando Vermelho (CV) in 2026. The shift brings these groups within US counter-terrorism frameworks, with implications beyond US borders. Commercial dealings previously assessed primarily through money laundering or sanctions frameworks may now also raise liability risks under existing prohibitions on providing “material support” to designated organisations.

For financial institutions and other businesses, the consequences are considerable. With criminal groups of this scale embedded in legitimate sectors such as fuel, logistics, gambling and financial services, exposure can arise in multiple ways. The designations also raise policy questions:

• whether a counter-terrorism tool is effective against profit-driven crime;
• how it interacts with local legal frameworks and domestic politics; and
• what it means for the traditional boundary between anti-money laundering, sanctions and counter-terrorist financing.

This session will examine the trend through the experience of several jurisdictions, with Brazil as a current case study. Speakers will discuss the legal architecture of FTO and related designations, the implications for US and international financial institutions and the interaction with local criminal, anti-corruption and anti-money laundering regimes. They will also consider what risk assessments, due diligence and escalation processes institutions need to put in place.