In brief: In May 2026 the United States designated Brazil's Primeiro Comando da Capital (PCC) and Comando Vermelho (CV) as terrorist organisations. Writing in O Estado de S. Paulo, Barry Wolfe argues that the decision "says less about the PCC and the CV than it does about Brazil". The PCC, he writes, is a Brazilian institution rather than an external threat, and it is present, directly or indirectly, in finance, agribusiness, logistics, energy and infrastructure. It rarely enters a business by force. It comes in through relationships of trust — suppliers, partners and intermediaries — and exploits the gap between how an organisation is supposed to work and how it actually does.
This is an English adaptation of an article first published in Portuguese in O Estado de S. Paulo on 20 September 2026. Quotations are translated from the original. Read the original in Estadão →
Background: the PCC, the CV and the designation The Primeiro Comando da Capital ("First Capital Command") was formed in São Paulo's prison system in the early 1990s and has grown into Brazil's largest criminal organisation, with operations across South America and links to Europe. The Comando Vermelho ("Red Command") emerged in Rio de Janeiro's prisons a generation earlier. The US State Department designated both as Specially Designated Global Terrorists on 28 May 2026 and as Foreign Terrorist Organisations with effect from 5 June 2026. State Department · Federal Register
Most commentary on the decision has focused on police co-operation, sanctions, drug trafficking and diplomacy. "All of that matters," Mr Wolfe writes. "But perhaps the more relevant question lies elsewhere: the decision says less about the PCC and the CV than it does about Brazil."
He draws a distinction between the two groups. The CV shows the classic traits of gangsterism. The PCC is different: its influence extends well beyond the urban peripheries and the prisons where it was born.
"It is a mistake to see the PCC as an external force. It is not. The PCC is a Brazilian institution. It emerged from the same social, economic and political conditions that shaped other organisations in the country."
Citing Michel Foucault's observation that the study of crime reveals how power operates within a society, he describes the PCC as "a diagnostic instrument".
In most of the world, Mr Wolfe argues, there is a border — imperfect, but real — between the formal economy and organised crime. In Brazil the picture is more complicated. Part of business and political life runs on "relationships of mutual compromise, favours, reciprocal dependencies and shared vulnerabilities". Brazilians have a phrase for it: rabo preso — literally "a tail caught in the door", meaning someone too compromised to speak out or walk away.
In classic mafia theory, he notes, the closest equivalent is omertà: a system in which the fall of one threatens all the others.
"The PCC does not need to create these networks. Its strategic asset is not violence, but the ability to exploit relationships of trust that already exist."
The organisation thrives where institutions tolerate opacity, crossed loyalties and informal structures of power. The paradox, he writes, is that mafia logic shows itself more intensely in certain political, financial and business circles than in the PCC's own structure.
According to Mr Wolfe, the PCC is present, directly or indirectly, in activities linked to:
"Whether or not one agrees with the American designation," he writes, "this is a reality that cannot be avoided."
Context: the fuel-sector investigation In August 2025 Brazilian authorities launched Operation Carbono Oculto ("Hidden Carbon"), one of the largest actions against the PCC's finances. Investigators alleged that the group had penetrated the fuel supply chain — affecting around 1,000 petrol stations — and laundered proceeds through fintechs and more than 40 investment funds, some linked to São Paulo's financial district, Faria Lima. InSight Crime · AP/PBS
Mr Wolfe draws on more than 40 years of corporate investigations, crisis management, anti-corruption work and organised-crime cases. The lesson he returns to is consistent:
"Criminal organisations rarely enter by force. They come in through relationships of trust — through connections, suppliers, partners, service providers, intermediaries and apparently legitimate ties. By the time they are discovered, they are often already part of the system."
"The challenge is no longer just compliance," he writes. Every organisation contains a degree of what he calls ethical entropy: rules are relaxed, procedures circumvented, personal relationships come to weigh more than principles, and small exceptions harden into accepted practice.
"Organised crime does not create this entropy. It merely accelerates processes of degradation already under way."
Every organisation, he argues, has two structures. The formal one appears on the organisation chart and defines how the organisation ought to work. The informal one — made up of trust, loyalties, favours and networks of influence — determines how it actually works. Real protection depends on the organisation's actual culture, not only on controls and audits, and on a permanent crisis-management capability rooted in both structures.
"There is no point in having a sophisticated code of ethics if the efficient but unethical executive is promoted while the person of integrity is sidelined."
Criminal organisations evolve faster than the bureaucracies built to fight them. In Mr Wolfe's experience, "the real challenge is rarely the infiltration itself, but the moment it is discovered". And in Brazil, the gravest risks are not always the ones already identified.
Context: why this matters outside Brazil The designation carries consequences beyond Brazil's borders. Providing "material support" to a Foreign Terrorist Organisation is a federal crime in the United States, and any transaction routed through the US financial system or denominated in dollars can fall within American jurisdiction. For multinationals, lenders and investors with Brazilian counterparties, exposure to the PCC is no longer only a reputational or local-law risk. State Department
"Just as the subconscious is a reflection of the conscious mind, the criminal underworld is a mirror reflecting a society's values, inequalities, power structures and tensions. Designating the PCC a terrorist organisation does not create a different reality. It merely illuminates one that already existed. Perhaps the reflection is more disturbing than the PCC itself."
Read the original article in Estadão (Portuguese) →
What is the PCC?
The Primeiro Comando da Capital is Brazil's largest criminal organisation. It was formed in São Paulo's prison system in the early 1990s and operates across South America. The United States designated it a terrorist organisation in 2026.
Does the PCC operate in Brazil's legitimate economy?
According to Barry Wolfe, the PCC is present, directly or indirectly, in activities linked to the financial system, agribusiness, logistics, construction, mining, energy, commerce, transport, betting and infrastructure.
How does organised crime infiltrate companies in Brazil?
Rarely by force. It enters through relationships of trust: suppliers, partners, service providers, intermediaries and apparently legitimate connections.
What is "rabo preso"?
A Brazilian expression for being compromised — bound by favours, dependencies or shared vulnerabilities that make it impossible to speak out or walk away. Barry Wolfe compares it to the mafia's omertà.
Why is compliance not enough to prevent infiltration?
Because controls address an organisation's formal structure, while infiltration exploits the informal one: loyalties, favours and networks of influence. Protection depends on the organisation's real culture.
Where was Barry Wolfe's article published?
In O Estado de S. Paulo, one of Brazil's leading newspapers, in its Espaço Aberto opinion section on 20 September 2026, under the title "O PCC não é uma anomalia. É um sintoma".
Barry Wolfe is the founder of Wolfe Associates, an international lawyer and criminologist. He holds a degree in Law and Criminology from the University of Edinburgh, was a Graduate Fellow at Yale Law School, and holds a master's in Public International Law from the University of Cambridge.
Wolfe Associates is a São Paulo law firm advising companies and banks on governance and protection against infiltration by organised crime. Contact us.
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