New York, NY – September 8, 2026 — How do companies manage FTO risk in Brazil following the recent designation?
That question was at the center of a recent discussion hosted by the Brazilian-American Chamber of Commerce, Inc., where Mintz Group's Sam Taylor explored how Foreign Terrorist Organization (FTO) designations could reshape compliance expectations for companies operating in higher-risk environments.
Some key takeaways Sam offered after this illuminating discussion:
- The diligence bar is rising. One-time background checks are no longer enough. Continuous monitoring and risk-based due diligence are becoming essential.
- Beneficial ownership matters. The greatest risks are often hidden behind vendors, partners, and intermediaries, making ownership and control mapping critical.
- Unknowns can be findings. In some environments, the inability to safely verify information may be an important risk indicator in itself.
We are grateful to the Brazilian-American Chamber for hosting a timely discussion on the evolving intersection of compliance, investigations, and third-party risk.