Treasury Sanctions Brazilian Criminal Network Linked to PCC Exploiting U.S. Financial System to Launder Drug Proceeds

On July 1, 2026, the U.S. Department of the Treasury’s Office of Foreign Assets Control (“OFAC”) designated two Brazilian nationals, three Brazilian companies, and one Portuguese company for their links to Primeiro Comando da Capital (“PCC”), described in the OFAC press release as the largest transnational criminal organization (“TCO”) in the Western Hemisphere.¹OFAC, Treasury Sanctions Brazilian Criminal Network Exploiting U.S. Financial System to Launder Drug Proceeds, July 1, 2026, available here. The action was taken pursuant to Executive Order 14059, which targets the proliferation of illicit drugs, and Executive Order 13224, as amended, which targets terrorists and their supporters.

The designations target an alleged São Paulo-based money-laundering network that allegedly used cryptocurrency to move more than $30 million in illicit drug proceeds through the U.S. financial system on behalf of PCC, according to OFAC.²Id. This action was coordinated with the U.S. Department of Justice (“DOJ”) and follows the January 2026 arrest by the FBI of six members of a Florida-based PCC cell on money-laundering charges in the Southern District of Florida.³Id.

This is OFAC’s third action targeting the PCC network and reflects the continued escalation of U.S. government enforcement activity against foreign terrorist organizations (“FTOs”), as we have highlighted in previous articles.⁴See Brazil: The Next Front in the Battle Against FTOs - Implications for U.S. and Brazilian Businesses of the Designations of Brazilian Criminal Organizations PCC and CV as Foreign Terrorist Organizations, (May 29, 2026), available here; see also Preparing for Mexican Drug Cartels’ Terrorist Designation, (Jan. 13, 2025), available here; King & Spalding, State Criminal and Civil Liability for Material Support: How the FTO Designation of Drug Cartels Increases the Risk of State Enforcement, (Mar. 11, 2025), available here ; Recent FTO Designations Raise FCA Liability Concerns for Multinational Organizations, (Mar. 31, 2025), available here; Drug Cartel Designations as FTOs Increase Financial Institutions’ Civil Liability Risks Under the Antiterrorism Act, (Apr. 18, 2025), available here;  Brazil: The Next Front in the Battle Against FTOs? Implications for U.S. and Brazilian Businesses of the Potential Designation of Brazilian Criminal Organizations as Foreign Terrorist Organizations, (May 19, 2026), available here. The designations carry significant implications for U.S. and Brazilian financial institutions, multinational companies, and entities involved in financial transactions with a nexus to Brazil.

Background

PCC and Its Global Reach. The PCC is reported to be Brazil’s largest and most organized criminal network, with a presence in multiple countries, including the United States, the United Kingdom, Turkey, Japan, and Paraguay.⁵OFAC, Treasury Sanctions Brazilian Criminal Network Exploiting U.S. Financial System to Launder Drug Proceeds, July 1, 2026, available at https://home.treasury.gov/news/press-releases/sb0549 The U.S. Treasury has described PCC as representing a significant threat to U.S. national security, with operatives throughout the United States, particularly in Florida, laundering drug proceeds through the U.S. financial system.⁶Id.

Prior OFAC Actions Against PCC. The PCC was initially designated as a Specially Designated Narcotics Trafficker (“SDNT”) in 2021.⁷U.S. Department of Treasury, Treasury Sanctions Primeiro Comando da Capital (PCC) Operative, (Mar. 14, 2024), available at https://home.treasury.gov/news/press-releases/jy2180. In March 2024, OFAC designated Diego Macedo Gonçalves do Carmo, a PCC operative, for allegedly laundering approximately $240 million for the organization.⁸Id. In May 2026, the U.S. Department of State designated PCC itself as a Foreign Terrorist Organization (“FTO”) and a Specially Designated Global Terrorist (“SDGT”).⁹U.S. Department of State, Press Statement by Secretary Marco Rubio, Terrorist Designation of Comando Vermelho and Primeiro Comando da Capital (May 28, 2026), available at https://www.state.gov/releases/office-of-the-spokesperson/2026/05/terrorist-designation-of-comando-vermelho-and-primeiro-comando-da-capital/.

The Newly Designated Parties. In its July 1 action, OFAC further tightened enforcement pressure on PCC’s financial structure by designating the following individuals and entities:

Entities:

• Victory Trading Intermediação De Negocios Cobrancas E Tecnologia Ltda (“Victory Trading”) —Financial services company based in São Paulo, Brazil.
• Pixwave Solucoes De Pagamentos Ltda (“Pixwave”) — Construction company based in São Paulo, Brazil.
• Wave Construcoes Inteligentes Ltda (“Wave”) — Financial services company based in São Paulo, Brazil.
• Avenidas Flutuantes Unipessoal Lda —Transportation and storage company based near Lisbon, Portugal.

Individuals:

• Victor Henrique de Oliveira Shimada (“Shimada”) — The OFAC press release describes Shimada as a São Paulo-based operative who served as a key link between Florida-based PCC operatives and foreign drug traffickers. Shimada allegedly laundered more than $30 million in illicit proceeds using cryptocurrency to move funds back to Brazil on behalf of PCC.¹⁰Id. In January 2025, Shimada was briefly held under house arrest in Brazil for using Victory Trading to launder money stolen from a Brazilian soccer club. Shimada was designated pursuant to E.O. 14059 and E.O. 13224.¹¹Id.
• Stella Stefanie Nunes Henrique de Oliveira (“Stella”) — Described by OFAC as a close associate and relative of Shimada who has worked as his secretary and served as a broker for bulk cash pickups, providing critical logistical services that have supported Shimada and his network in their laundering operations. Stella was designated pursuant to E.O. 14059 and E.O. 13224.

Key Risks

In addition to the risks detailed in our previous publications,¹²See Brazil: The Next Front in the Battle Against FTOs - Implications for U.S. and Brazilian Businesses of the Designations of Brazilian Criminal Organizations PCC and CV as Foreign Terrorist Organizations, (May 29, 2026), available here; see also Preparing for Mexican Drug Cartels’ Terrorist Designation, (Jan. 13, 2025), available here; King & Spalding, State Criminal and Civil Liability for Material Support: How the FTO Designation of Drug Cartels Increases the Risk of State Enforcement, (Mar. 11, 2025), available here ; Recent FTO Designations Raise FCA Liability Concerns for Multinational Organizations, (Mar. 31, 2025), available here; Drug Cartel Designations as FTOs Increase Financial Institutions’ Civil Liability Risks Under the Antiterrorism Act, (Apr. 18, 2025), available here;  Brazil: The Next Front in the Battle Against FTOs? Implications for U.S. and Brazilian Businesses of the Potential Designation of Brazilian Criminal Organizations as Foreign Terrorist Organizations, (May 19, 2026), available here. the July 1 designations highlight risk categories for corporations and individuals with exposure to Brazil:

Financial Institutions and Virtual Asset Service Providers. Banks, money services businesses, fintech companies, and cryptocurrency exchanges processing Brazilian-origin transactions face heightened screening and reporting obligations. PCC’s reported use of cryptocurrency to launder $30 million in drug proceeds highlights potential vulnerabilities in virtual asset service providers and correspondent banking channels.

Multinational Corporations. Companies operating in Brazil, particularly in São Paulo, Rio de Janeiro, and sectors with exposure to PCC-linked financial infrastructure, may face inadvertent exposure through vendor relationships, financial transactions, or third-party service providers connected to designated entities.

Non-U.S. Financial Institutions. Non-U.S. financial institutions, particularly those in Brazil and Portugal, face secondary sanctions risk for conducting or facilitating significant transactions on behalf of designated persons. The designation of a Portuguese entity signals OFAC’s willingness to follow PCC’s financial networks across jurisdictions.

Recommended Actions

In light of the July 1 designations, companies and financial institutions should promptly¹³See also our recommendations in the article Brazil: The Next Front in the Battle Against FTOs - Implications for U.S. and Brazilian Businesses of the Designations of Brazilian Criminal Organizations PCC and CV as Foreign Terrorist Organizations, (May 29, 2026), available here.:

• Update Sanctions Screening. Immediately incorporate today’s designated individuals and entities into sanctions screening systems and lists; include all name variations, aliases, and entities owned 50% or more by designated persons.
• Conduct a Privileged Risk Assessment. Assess potential exposure to PCC-linked persons across operations, financial transactions, vendor relationships, and supply chains involving Brazil.
• Review Third-Party Relationships. Evaluate vendor, counterparty, and financial service provider relationships in Brazil for potential sanctions risk, including logistics companies and local intermediaries.
• Review Whistleblower Intake Mechanisms. Ensure internal reporting and whistleblower processes are adequate, particularly in light of the fact that the FinCEN whistleblower program provides direct financial incentives for reporting suspected violations.
• Strengthen KYC/AML Programs. Ensure that know-your-customer, anti-money-laundering, and beneficial-ownership processes can detect accounts or transactions linked to designated persons, particularly given PCC’s use of front companies across multiple jurisdictions.
• Enhance Cryptocurrency Monitoring. Review blockchain analytics capabilities and transaction-monitoring rules to detect patterns associated with cryptocurrency-based laundering, given the central role of virtual assets in PCC’s financial operations.
• Monitor Regulatory Developments. Anticipate further OFAC designations, FinCEN advisories, and DOJ enforcement actions targeting PCC’s U.S. financial infrastructure.

Conclusion

The July 1 OFAC designations are the latest in a series of escalating U.S. government actions targeting criminal organizations in Brazil and carry substantial implications for entities with financial or business exposure to Brazil. The coordinated Treasury-DOJ enforcement approach, the focus on cryptocurrency-based laundering, and the cross-jurisdictional scope of the designations signal that U.S. authorities are aggressively pursuing FTO’s global financial networks.

As highlighted in previous articles, companies and financial institutions must immediately assess their compliance systems, screening capabilities, and third-party relationships to identify and mitigate the risks flowing from these designations. Prompt action is essential to avoid potential civil or criminal liability.

This alert provides a general summary of recent legal developments. It is not intended to be, and should not be relied upon as, legal advice. In some jurisdictions, this may be considered attorney advertising.