The Dialogue = Financial Services Advisor. July 14, 2026
Pedro Fragoso Pires, foreign legal consultant, and Veronica Mayoral, law clerk, both at Diaz Reus International Law
Firm: “Specially designated global terrorist (SDGT) designations carry civil liability, specifically financial and economic sanctions for noncompliance. Any U.S. financial institution or Brazilian lender with ties to the United States that holds funds or assets owned by these gangs must immediately block them and report them to OFAC.
As the PCC and CV have infiltrated sectors of the Brazilian economy, combining lawful and unlawful activity, the scrutiny process has become even more challenging and critical. Foreign terrorist organization (FTO) designations
carry criminal liability with extraterritorial jurisdiction.
