On May 28, 2026, the U.S. Department of State designated Brazil's two largest criminal organizations — the Primeiro Comando da Capital (PCC) and the Comando Vermelho (CV) — as Specially Designated Global Terrorists, with full Foreign Terrorist Organization status effective June 5, 2026. This is, first and foremost, a political decision by the Trump administration — but the consequences for anyone doing business in Brazil are real. Below I explain why the PCC is fundamentally different from traditional mafias, why Brazilian corporate corruption has more classic mafia characteristics than the PCC itself, and how businesses and families can operate with integrity in Brazil without stepping into what I call "the swamp."
If you are reading this from outside Brazil, you may not know exactly what the PCC and Comando Vermelho are. Both are Brazilian criminal networks that emerged from the prison system, and together they have more than 50,000 members.
These are not ideological groups. They are organizations built to make money — mainly from drug trafficking, extortion, and increasingly from infiltration of the formal economy.
The classification as terrorist organizations is not a careful technical analysis of the nature of these groups. It is a political decision by the Trump administration, a modern extension of the Monroe Doctrine.
What is the Monroe Doctrine? A U.S. foreign policy principle from the early 19th century declaring that Latin America falls within the U.S. sphere of influence. Today, the Trump administration is applying that logic in modern form — asserting more American authority over the region.
I am not particularly interested in debating whether the PCC deserves the label. I am interested in what this specific designation, applied to Brazil, means in practice. Because Brazil is different from other countries. And the PCC is a very particular phenomenon, deeply connected to the way Brazilian society itself works.
Hypothetically, yes — as happened with Venezuela. In practice, I do not believe we will see American military action inside Brazil.
What the designation more realistically opens is this: today, the FBI and Brazil's Federal Police have a fairly cordial cooperation. With this designation, that cooperation may intensify — and, more importantly, the CIA may also enter the picture.
This is not speculation. Brazilian investigators specialized in organized crime have already warned that the designation could shift operational coordination from the FBI and DEA toward the CIA — an agency with an entirely different mandate.
Many people conflate them. The distinction matters:
The designation opens the possibility that the CIA believes it now has more latitude to operate in Brazil. It's not a certainty — it's an open door.
A former CIA colleague of mine at Control Risks once put it perfectly: "You know the difference between a police officer and a spy? The policeman always finds a way to show you he's carrying a gun. The spy never shows the gun."
The impact is not "immediate" in the sense of tomorrow morning. But companies and banks doing business in Brazil now have to substantially raise their compliance posture to protect against U.S. actions such as:
What is compliance, in one line? It's the set of internal rules, controls and verifications a company uses to make sure it does not, even unintentionally, get involved with illegal money or people.
Here is the detail most non-financial people don't realize: most international dollar transfers pass through the United States, even when nobody is sending money to or from an American account.
Example: you wire money from Brazil to France. That money does not go directly. It passes through a correspondent bank in the United States.
What is a correspondent bank? A U.S. bank that acts as an intermediary for international operations of other banks. Almost every dollar that moves across borders in the world touches one of these correspondent banks at some point.
That means a transaction between Brazil and France can be blocked, delayed, or investigated by a U.S. bank that becomes suspicious of any endpoint of the operation. Banks will now be watching Brazilian flows very closely. The game has changed.
Whenever a foreign company invests in Brazil, it performs due diligence — checking who the target company is, who the partners are, whether the people involved are trustworthy.
What is due diligence? The investigation you carry out before investing in a company. Who owns it, what its history is, whether there are lawsuits, whether the principals have suspicious backgrounds.
That process now has to extend to the entire web of relationships — commercial partners, suppliers, clients — to identify any possible connection to organized crime, and specifically to the PCC or Comando Vermelho.
Organized crime has been my professional obsession since I was fifteen years old, when I read The Godfather and started giving school presentations on the structure of the Italian mafia while my classmates were presenting on football and cars. I studied criminology at university. I have spent decades investigating these structures.
Something I have observed for a long time: you can recognize a mafia by how it appears in society.
In Brazil, you will never see the head of the PCC at the Copacabana Palace. They stay hidden. It is another story entirely.
The PCC and Comando Vermelho are, in their essence, gangster groups with military and territorial power. They are not mafias in the classical sense.
Traditional mafias operate what is called a protection racket.
What is a protection racket? A specific form of extortion. The mafia approaches a business owner and says: "If you want to operate here, you have to pay us. Pay us to protect you… from us."
In Brazil, the PCC does not need to do this. Why?
Because the parallel protection structure already exists inside the large corruption schemes of Brazilian society. My former boss at Control Risks — a brilliant former CIA officer — explained it to me when I first arrived:
"In Brazil, if you're not a genius, to grow big and grow fast, you have to have rabo preso. You have to be part of a network of compromised people. Because once your rabo is caught — if one falls, everyone falls."
That is the essence of it. Brazilian business owners who grow fast spend their lives keeping track of who knows what about them.
What does "rabo preso" mean? Literally "tail caught" or "tail tied." It's a Brazilian expression describing people mutually implicated in something — usually something they cannot afford to have exposed. Each holds compromising knowledge about the others. Nobody can talk without bringing everyone down.
The classical Sicilian-American mafia has a concept called omertà. To be accepted into the mafia, the initiate had to kill someone. Why kill? So that the others knew — creating shared, unspeakable knowledge that bound everyone together.
Brazilian "rabo preso" performs the same structural function. Except in Brazil, it operates inside the ordinary business world — not inside a formal criminal organization. It is embedded in the culture.
That is exactly why the PCC does not need its own sophisticated extortion network. The rabo-preso network is already there — in big business, in politics, in power structures. The PCC simply inserts itself into an ecosystem already built for concealment.
Here is the most interesting — and most paradoxical — thing about crime in Brazil.
The PCC began as a social movement, in response to the Carandiru massacre.
What was the Carandiru massacre? In October 1992, military police stormed the Carandiru prison in São Paulo, killing 111 inmates. It became one of the most infamous human rights episodes in modern Brazilian history. Two years later, the PCC was founded — initially as an organization to protect inmates from state violence, before evolving into what it is today.
And yet, in Brazil, the entities with the most archetypal mafia characteristics are not the PCC. They are the large Brazilian businesses — with their institutionalized corruption networks, their rabo-preso structures, their systematic impunity.
It is a fascinating paradox. In Brazil, you cannot separate the PCC-type of organized crime from the corrupt segment of the corporate world. It is all part of the same fabric. One reflects the other. Both are institutionalized. You cannot remove one without removing the other. This is part of Brazil.
If you are a business owner, a banker, or an investor, and you want a life of integrity in Brazil, you have to build a world in which you do not touch these things.
I compare it to walking through a beautiful forest. The forest is stunning — worth exploring, worth being in. But there is a swamp hidden inside it. If you step into the swamp, it pulls you in. You get stuck. You do not come out.
So what do you do? You make a map. You plan your route. You never even go near the swamp. Because the moment you get close, you are already lost.
Brazil has institutionalized corruption. But the Brazilian people are wonderful. They have been exploited, but they are good people. That is why I came to Brazil. That is why I stayed.
It is entirely possible to build a world of integrity inside a company, inside a family. You simply cannot touch the swamp.
There is a concept in physics called entropy.
What is entropy, simply? Organized things tend, over time, to become disorganized. A glass falls and breaks. You never see the pieces spontaneously reassemble into a glass again.
There is such a thing as moral entropy. Social entropy. A society that decays does not go back to its prior state on its own. If you want the glass whole again, you have to pick up every piece and rebuild it, patiently, one by one.
But I am an optimist. I believe it is possible. Imagine a dirty glass with dirty water in it. If you start dripping clean water into it, at first it makes no difference. But eventually, if you also stop the dirty water from coming in, the water in the glass starts to become clearer.
You need external input — someone bringing a different perspective. It's slow, but it's possible.
Under international law, the difference is clear:
The two can help each other — there are cases of terrorist groups involved in trafficking, and cases of criminal organizations with political connections. But at their core, they are different things.
The FARC in Colombia began with political ends and later also became criminal — it was, correctly, designated a terrorist organization. That is not the case with the PCC or Comando Vermelho. Their objective is money.
That is why the U.S. designation is, in the end, primarily a political move rather than a technical one.
Michel Foucault observed that the way a country punishes its criminals reveals the power structures of that society.
In Brazil, what reveals the power structures is the inverse: the way Brazil frequently does not punish. Who escapes punishment, who enjoys special legal protections, who never actually reaches trial — that map of impunity is the real map of power.
Brazilians are extraordinarily creative. In music. In art. Also in crime.
You will never be able to map all the risks in Brazil, because you will never be able to predict what a Brazilian will invent. Nobody could have imagined the audacity of the recent Daniel Vorcaro / Banco Master case — it was unthinkable.
Who is Daniel Vorcaro? A Brazilian banker whose 2025 arrest triggered one of the largest banking fraud cases in Brazilian history, involving political connections and financial system captures at the highest levels.
Why did he dare so much? Because he believed in impunity. He believed everyone was compromised, that everyone had rabo preso, and therefore nobody would truly punish him.
You can build a business of integrity. You can build a family of integrity. And it all starts at home.
Children know who their parents really are. Employees know who the owner of the company really is. The chief executive can speak of ethics all day — but if he does not act ethically, everyone knows.
Every company has its formal side and its informal side. Genuine ethical posture is detectable. Companies have to be internally dignified. And from that base, you build a world of integrity inside Brazil.
Little by little, things get better.
Hypothetically yes, as happened with Venezuela. In practice, the more likely scenario is intensified police cooperation and possible CIA involvement — not open military intervention.
Yes, considerably. Because most international transactions pass through U.S. correspondent banks, and those banks will now apply much heavier compliance scrutiny to any operation touching Brazil.
Due diligence will need to be substantially broader. Analyzing the target company alone is no longer sufficient — investors will need to examine the entire web of relationships (partners, suppliers, clients) for possible ties to the PCC or Comando Vermelho.
Traditional mafias operate organized extortion (protection rackets) and appear openly in elite society. The PCC does neither — it doesn't need to, because the "rabo preso" network of mutual compromise already exists inside Brazilian business and political culture.
By mapping the "forest" — identifying where the "swamps" of institutional corruption are — and structuring the entire business life to never go near them. And by starting that discipline at home, in the family.
No. Terrorism has political objectives. Organized crime has economic objectives. They may cooperate opportunistically, but their fundamental motivations are different.
Brazil has institutionalized corruption. That is a fact. But Brazil also has a remarkable population, and it is possible to live with integrity here — if you know where the swamp is and have the discipline to stay away from it.
It starts in the family. It extends into the business. Little by little, things get better.
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