Matteson Ellis authored this article in Americas Quarterly discussing the compliance implications of the U.S. designation of major Brazilian criminal organizations as Foreign Terrorist Organizations (FTOs). Ellis explained that companies in the region run the risk of transacting with these FTOs, adding that "ostensibly normal business activities could now constitute civil and criminal offenses under U.S. law." Ellis highlighted that these unprecedented designations create "significant new risks for businesses," and require companies in Brazil to reassess due diligence and internal compliance protections as enforcement intensifies and expectations continue to evolve.