June 29, 2026

Michel Sancovski Discusses the Risks of the U.S. Designation of Brazilian Criminal Organizations as Terrorist Groups in Dow Jones Risk Journal Webinar

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Discussions surrounding the implications of the United States' designation of Brazil's Primeiro Comando da Capital (PCC) and Comando Vermelho (CV) as terrorist organizations continue to gain momentum internationally, particularly regarding the regulatory, financial, and compliance challenges facing businesses. Our partner Michel Sancovski, Co-Leader of the Global Investigations & White Collar Defense practice, participated in another important international discussion on the topic during the webinar "Risks for Companies in U.S. Targeting of Brazilian Criminal Groups," hosted by the Dow Jones Risk Journal.

The discussion was moderated by Nicholas Elliott, Vice President of Dow Jones Risk. The session examined the recent U.S. designation of two Brazilian criminal organizations as terrorist groups, a measure that expands the use of legal and financial enforcement tools by U.S. authorities in combating cartels and transnational criminal organizations.

Throughout the discussion, the speakers emphasized that the challenges facing companies extend well beyond traditional sanctions screening and due diligence processes. As criminal organizations become increasingly embedded in the formal economy, identifying potential exposure and effectively managing risk has become significantly more complex.

"The challenge for companies is not simply identifying sanctions or regulatory restrictions, but developing mechanisms capable of anticipating risks and understanding the increasingly complex connections between criminal organizations and the formal economy throughout the business value chain," said Michel Sancovski.

The panel also explored several key red flags for companies, including corporate structures lacking a clear economic rationale, businesses with financial activity inconsistent with their size or operations, and entities with little or no verifiable operating history.

The webinar further underscored that the evolving regulatory landscape requires an increasingly robust risk-based approach, with enhanced scrutiny of counterparties, third parties, and potentially sensitive business relationships. In this context, strengthening compliance programs, corporate investigations, and third-party risk management has become essential for companies seeking to mitigate their exposure amid evolving regulatory expectations and enforcement trends.

Watch the full webinar in this link

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