By Martha Araujo Hager, Of Counsel.
In July 2025, the U.S. Department of the Treasury’s Office of Foreign Assets Control (OFAC) sanctioned Brazilian Supreme Court (Supremo Tribunal Federal, STF) Justice Alexandre de Moraes under the Global Magnitsky Human Rights Accountability Act (GLOMAG). Weeks later, the Brazilian Supreme Court issued a binding opinion (in Instituto Brasileiro de Mineração v. Município de Acaiaca et al.) holding that orders issued by foreign authorities are unenforceable in Brazil, except when authorized by Brazilian law or Brazilian courts.
Under U.S. law, U.S. citizens, permanent residents, U.S. incorporated entities and their foreign branches, must comply with OFAC sanctions. Non-U.S. persons are subject to OFAC sanctions when they cause or conspire to cause U.S. persons or entities to violate sanctions, or when they assist sanctioned persons or entities to evade sanctions.
