Billion-Dollar Blind Spot

Brazil’s most prominent transnational criminal organization—Primeiro Comando da Capital (PCC)—continues to operate its global network despite U.S. sanctions and decades of law enforcement efforts. C4ADS uncovered Florida-registered companies tied to three alleged PCC members and money launderers, exposing how even red-flagged networks can access the U.S. financial system. The ongoing activities of the Bozhanaj-Cazula network, as well as an earlier case study of the Yamawaki network, show how the PCC exploits systems from banking to diplomatic relations, infiltrates domestic politics, and collaborates with transnational criminal organizations (TCOs) and their agents worldwide—from Latin America to the United States to Europe to China.

INTRODUCTION #

On August 28, 2025, Brazil launched Operation Carbono Oculto, reportedly the largest police operation targeting organized crime in its history.^[1] As part of Operation Carbono Oculto, at least 1,400 law enforcement agents executed 200 search and arrest warrants against 350 individuals and companies across 10 Brazilian states. The ongoing operation seeks to dismantle a network of individuals and companies accused of laundering money for the TCO Primeiro Comando da Capital (PCC).^[2] In São Paulo’s Faria Lima financial district—known as the Brazilian Wall Street—alone, the police served warrants at 42 fintech, real estate, and asset management firms.^[3] PCC’s infiltration of financial systems is not restricted to Brazil. Publicly available information exposes how the criminal group has extended its malign presence internationally, including in the United States.

Founded in 1993 by eight inmates at the Taubaté Penitentiary in São Paulo, PCC has since expanded to a network of an estimated 40,000 members^[4] operating across five continents in at least 29 countries.^[5] While the PCC’s expansion was predominantly fueled by drug trafficking, which it likely continues to prioritize, it is now a “multinational of crime,” infiltrating multiple sectors in Brazil and worldwide.^[6]

When the U.S. Department of the Treasury sanctioned the PCC in December 2021, it described the group as “the most powerful organized crime group in Brazil and among the most powerful in the world.”^[7] In January 2024, the Brookings Institution called the PCC “a transnational criminal ‘leviathan’,”^[8] and in February 2025, The Washington Post described it as “South America’s most powerful drug-trafficking gang.”^[9] Despite its notoriety within law enforcement and policy circles, the PCC—and its access to the U.S. financial system—remain virtually unknown to the U.S. public.

By leveraging publicly available corporate, judicial, and police records in the United States and Brazil, C4ADS identified an active Florida company, Bozhanaj Group Corporation, that may be servicing two alleged PCC members: Marinel Bozhanaj and Sebastião Cazula. C4ADS also uncovered alleged PCC money launderer João Gabriel de Mello Yamawaki’s Florida-registered companies from 2017.

THE BOZHANAJ-CAZULA NETWORK #

With well-reported ties to Brazil, the United States, Albania, and China, the Bozhanaj-Cazula network illustrates how the PCC has access to the U.S. financial system. This access allows it to launder the proceeds of its illicit activities that pose a major threat to global security through systematic infiltration of sectors from fuel to drug trafficking to the international weapons trade.^[10] 

Police Scrutiny

Over the last decade, as the PCC grew and forged alliances with criminal groups across the Americas and Europe, Brazilian law enforcement launched operations targeting the group’s networks of enablers and international partners. By 2024, the Brazilian Federal Police had zeroed in on Cazula^[11] and Bozhanaj^[12] as potential members of schemes to launder ill-gotten gains and facilitate shipments of cocaine from Brazil to Europe, respectively.^[13]

In May 2024, Brazilian Federal Police launched Operation Pallium. Its agents executed search warrants in 10 Brazilian cities in pursuit of a network that allegedly laundered at least 120 million Brazilian reais (approximately US$22 million) for drug trafficking organizations.^[14] Legal documents made public by the 10th Federal Criminal Court of São Paulo in September 2024 identified Edenilson Sebastião Cazula,^[15] vice president of the Brazil-China Chamber of Commerce for International Development (Câmara de Comércio de Desenvolvimento Internacional Brasil-China or CCDIBC), as the head of the network. Cazula was no stranger to Brazilian federal investigators. In March 2015, the Brazilian Federal Public Prosecutor’s Office publicly accused Cazula of using a shell company, Comércio, Indústria, Importação e Exportação Ltda., in Natal, Brazil, to launder money and evade taxes, sending millions of dollars abroad.^[16]

In December 2024, the Brazilian Federal Police and the Italian Anti-Mafia Directorate of the Turin Prosecutor’s Office launched a joint operation targeting PCC’s partnerships with Italian and Albanian criminal syndicates to ship cocaine from Brazil to Europe, dubbed Operation Mafiusi by Brazilian authorities and Operation Samba^[17] by their Italian counterparts.^[18] A 2024 Brazilian Federal Police report on Operation Mafiusi described Bozhanaj as “an Albanian, nicknamed ‘the German,’ who was responsible for welcoming and supporting Albanian drug traffickers interested in setting up […] operations in Brazil.”^[19] In March 2025, the Brazilian newspaper Metrópoles reported that Bozhanaj and William Barile Agati were two of four PCC members who had attempted to gain diplomatic immunity in Brazil by bribing Mozambique’s then-honorary consul in Brazil, Deusdete Januário Gonçalves, in exchange for employment at the Mozambican Consulate in Belo Horizonte, presumably to avoid criminal exposure.^[20] The Brazilian Federal Police indicted Agati in February 2025 on charges related to drug trafficking, including acting as a middleman between PCC and European criminal syndicates such as the ‘Ndrangheta.^[21]

The Florida Connection

While Bozhanaj and Cazula faced allegations in Brazil of involvement in international drug trafficking in separate Brazilian Federal Police investigations, no public reporting has linked them. C4ADS identified documents establishing a corporate connection between the two men, not in Brazil, but in the United States.

The Florida corporate registry shows that Bozhanaj and Cazula registered a company together in Miami, Florida, on August 30, 2023.^[22] The company, Bozhanaj Group Corporation, is still listed as active, with Bozhanaj listed as its vice president.^[23]

In 2024, corporate filings for the Bozhanaj Group Corporation stopped listing Cazula as an officer of the company, showing Bozhanaj and a woman named Jessica C. Scotton as its sole officers.^[24] However, Cazula still has access to the U.S. financial system through companies registered by him and his wife and daughter: New Alliance Export Trading LLC^[25] and Xossi International Freight LLC,^[26] respectively. In addition, both of these companies share a mailing address with Bozhanaj Group Corporation.^[27]

The presence of these entities in corporate documents, as well as the fact that they all share the same mailing address, points to continued collaboration between Bozhanaj and Cazula on U.S. soil. 

Brazilian law enforcement has been aware of Cazula’s presence in Florida, just as U.S. law enforcement has known of the PCC’s ability to launder money in the United States. According to the judicial documents published in September 2024, Cazula owned an apartment in Miami.^[28] The PCC successfully moved tens of millions of dollars across international borders in 2014, using banking systems in the United States and China to launder their drug money.^[29] Key operatives—including one of the PCC’s then-largest cocaine suppliers, Gilberto Aparecido dos Santos, aka “Fuminho” in Florida, along with PCC finance man Wilson José Lima de Oliveira, known as “Neno”—were reportedly running these operations from U.S. soil while coordinating a major cocaine supply network.^[30]

In addition to his companies in Florida, Brazilian corporate record aggregators indicate that Cazula is also an officer of at least two Brazil-registered companies, Czl Storage Logistica and Dannenberg Importadora e Exportadora de Maquinas e Produtos Texteis Ltda.^[31] Additionally, the Panama Papers list him as the shareholder of one Seychelles-registered company.^[32]

The China Connection

News and social media indicate that Cazula’s international network has strategic ties to China, suggesting broader cooperation that may run counter to U.S. national interests.In April 2025, the Brazil-China Chamber of Commerce for International Development uploaded multiple posts to its website describing Cazula as its vice president and the CEO of New Alliance Export Trading, noting that Cazula had recently traveled to Beijing as part of a CCDIBC delegation to promote trade between Brazil and China.^[33] The CCDIBC is a São Paulo-based organization founded in 2002 by Chinese businessmen living in Brazil and led by Fábio Hu.^[34] On its website, the organization claims to be supported by multiple municipal and provincial Chinese governments, including Beijing, Shanghai, Guangdong, Zhejiang, Sichuan, and Harbin.^[35]

Though the exact nature of their relationship and activities are unknown, Hu has posted photos of himself attending social events with Cazula as recently as August 28, 2025.^[36] On July 10, 2025, the CCDIBC’s webpage published an article announcing that the state of São Paulo had awarded Hu the newly created Armando Romagnol Medal, awarded to individuals who “have made outstanding contributions to São Paulo society and to the preservation of democratic ideals.”^[37] In the article, Hu is pictured posing both with Cazula and the Mayor of São Paulo, Ricardo Nunes, and with São Paulo Governor Tarcísio de Freitas next to São Paulo State Military Police officers.^[38]

THE YAMAWAKI NETWORK #

The Bozhanaj-Cazula network exemplifies just one instance of a broader pattern of Brazilian TCOs exploiting the U.S. financial system. C4ADS has identified another individual accused of laundering money for PCC who had established a corporate presence in Florida. This case study exemplifies the role of fintech in PCC money laundering, the PCC’s close connections to local politicians, and how these networks may connect to the U.S. financial system. 

In August 2024, São Paulo State Civil Police agents arrested João Gabriel de Mello Yamawaki, a Brazilian businessman, in an operation targeting the PCC’s finances and its suspected infiltration of Brazilian municipal governments.^[39] Yamawaki was reportedly the ringleader of a scheme that used a Brazil-registered fintech company, 4TBank, and 19 other companies to launder more than 8.6 billion Brazilian reais, or almost US$1.75 billion, on behalf of the PCC.^[40] Fintech companies have been integral to PCC’s money laundering operations as they make it difficult to track transactions and, until Brazil’s Finance Minister Fernando Haddad announced a new rule on September 1, 2025,^[41] did not have to adhere to the same standards as traditional banks.^[42]

Yamawaki’s corporate presence has not been restricted to Brazil. According to the Florida corporate registry, Yamawaki registered two companies in the state in 2017: Las Americas USA LLC^[43] and Unique Business USA LLC.^[44] While both companies were dissolved the following year, two details about them stand out. First, corporate records for both companies list only two officers, Yamawaki and Agnes Miyuki Kawano, a former municipal official of the city of Palmas, Tocantins, Brazil, adding another thread to Yamawaki’s web of Brazilian municipal government connections. Second, one of Yamawaki’s Florida companies was directly linked to a digital payment company Yamawaki had registered in Brazil, making the financial ties between the allegedly PCC-associated companies in Florida and Brazil more explicit. The first corporate document for Yamakaki’s Las Americas USA LLC^[45] listed Las Americas Wallet S.A., a Brazilian debit card company registered in Tocantins in 2014 and dissolved in 2022, as its authorized member.^[46] The Brazilian corporate data aggregator platform Econodata listed João Gabriel de Mello Yamawaki as the CEO of Las Americas Wallet S.A.^[47]  Yamawaki attempted to register another business in Florida in 2020—Vulter Bridge International LLC—which was rejected for unknown reasons.^[48]

There is compelling evidence that the Yamawaki network not only likely laundered the PCC’s money, but it that it also allocated some of it to fund the political campaigns of city councilmember and mayoral candidates supported by the criminal group.^[49] According to São Paulo state Civil Police Chief Fabrício Intelizano, Yamawaki was responsible for financing the political campaigns of candidates favored by the PCC in municipal elections in the state of São Paulo in 2024.^[50] On August 7, 2024, the Brazilian newspaper, O Estado de S. Paulo, citing police documents and quoting Intelizano, reported that Yamawaki transferred funds to the political campaigns of Thiago Rocha de Paula and his girlfriend, Marie Sassaki Obam.^[51] Obam ran for a city councilmember position in the city of Mogi das Cruzes for the conservative party, União Brasil. De Paula ran for a city councilmember position in the city of Santo André for the centrist Partido Social Democrático. On December 3, 2024, Bloomberg News published a photo of Yamawaki standing next to a smiling Valdemar Costa Neto, the president of the far-right Partido Liberal.^[52] Information made available by Brazil’s electoral transparency portal indicates that Yamawaki has played a role in politics since at least 2004. According to the portal, Yamawaki ran for a city councilmember position in the city of Esperantina in the state of Tocantins in 2004 as a candidate for the leftist Partido dos Trabalhadores, receiving enough votes to become an alternate.^[53]

If the allegations against Yamawaki are true, his pattern of activity—supporting candidates across the ideological spectrum—illustrates the PCC’s interest in influencing municipal politics. In an interview published by O Estado de S. Paulo on June 2, 2025, Giovanni Bombardieri, Chief Prosecutor of the Antimafia Prosecution Office in Turin, stated that the Italian criminal syndicate ‘Ndrangheta has sought to infiltrate politics in the southern Italian region of Calabria by electing candidates to city councilmember and mayor positions regardless of party ideology.^[54] Bombardieri participated in the 2024 Operation Mafiusi, a joint Brazilian and Italian law enforcement action to dismantle the PCC and ‘Ndrangheta’s cocaine shipments from Brazil to Europe.^[55] It is possible that the PCC is attempting to replicate its Italian counterparts’ efforts to infiltrate municipal governments.

The Broader Picture: Implications For Law Enforcement And National Security #

The revelation that Bozhanaj and Cazula operate active companies in Florida—including a company they registered together—despite facing allegations of involvement in international drug trafficking overseas, exposes how even red-flagged networks can access the U.S. financial system and continue to operate worldwide. Yamawaki’s activities further illustrate the patterns of activity in Brazil and abroad that these individuals pursue, likely on behalf of the PCC.

South American and European criminal syndicates, including those from the Balkans and Italy, have demonstrated the interoperability necessary to move narcotics from the Western Hemisphere to Europe. For the last two decades, criminal networks from the Balkans and Italy have deepened their ties with South American TCOs—including by having some of their members move to the Western Hemisphere—to facilitate cocaine trafficking to Europe.^[56] Bozhanaj’s alleged role supporting Albanian criminals to set up drug trafficking operations in Brazil is emblematic of this ongoing trend. For example, a network of companies registered in Albania and the United States trafficked cocaine via banana shipments moving from Ecuador to Europe, as reported in June 2025 by Argentine news outlet Infobaewith data and analysis provided by C4ADS.^[57]

Well-connected businessmen play a critical role in enabling TCOs to access licit financial systems, political influence, and potential impunity. Cazula and Bozhanaj appear to have an international corporate presence. Bozhanaj’s reported scheme to gain employment as a Mozambican honorary consul in Brazil further showcases the PCC’s connections and influence within governments worldwide. Likewise, Yamawaki has been associated with at least one company in Brazil and at least two in the United States. His reported involvement in municipal campaign financing demonstrates the extent of the PCC’s integration into domestic politics as well as the importance the organization puts on those ties.

Florida—or perhaps its corporate regulatory system—continues to hold allure for TCOs seeking to place, layer, and integrate their ill-gotten gains in the United States. The above case studies illustrate how easily foreign actors with TCO ties can gain access to the U.S. financial system. The fact that Bozhanaj and Cazula continue to operate companies in Florida signals to TCOs that Florida, and potentially other U.S. states, are open for business.

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[1] Government of Brazil, “Operation Hidden Carbon: RFB and partner bodies fight organization responsible for evasion and money laundering in the fuel sector,” Ministry of Finance, August 28, 2025, https://www.gov.br/receitafederal/pt-br/assuntos/noticias/2025/agosto/operacao-carbono-oculto-rrb-e-orgaos-parceiros-combatem-organizacao-responsavel-por-sonegacao-e-lavagem-de-dinheiro-no-setor-de-combustiveis.

[2] Fausto Macedo, “Maior operação contra crime organizado no País atinge Faria Lima e setor de combustíveis,” Estadão 150, August 28, 2025, https://www.estadao.com.br/politica/blog-do-fausto-macedo/maior-operacao-contra-crime-organizado-no-pais-atinge-faria-lima-e-setor-de-combustiveis/.

[3] Macedo, “Maior operação contra crime organizado no País atinge Faria Lima e setor de combustíveis.”

[4] Alfredo Henrique and Felipe Resk, “DE 8 A 100 MIL,” Metrópoles, August 30, 2023, https://www.metropoles.com/materias-especiais/pcc-completa-30-anos-com-exercito-de-100-mil-a-servico-do-trafico.

[5] Helena Barra and Ana Julia Bertolaccini, “PCC se espalha em 28 países com mais de 2 mil integrantes; veja lista do MPda CNN,” CNN Brazil, June 24, 2025, https://www.cnnbrasil.com.br/nacional/brasil/pcc-se-espalha-em-28-paises-com-mais-de-2-mil-integrantes-veja-lista-do-mp/.

[6] Roberto Uchôa, “From Drug Trafficking to Faria Lima: The PCC’s Metamorphosis into a Corporate Conglomerate and the Threat to the Economy,” Small Wars Journal, August 30, 2025, https://smallwarsjournal.com/2025/08/30/from-drug-trafficking-to-faria-lima-the-pccs-metamorphosis-into-a-corporate-conglomerate-and-the-threat-to-the-economy/.

[7] Government of the United States, “Treasury Uses New Sanctions Authority to Combat Global Illicit Drug Trade,” Department of the Treasury, December 15, 2021, https://home.treasury.gov/news/press-releases/jy0535.

[8] Valerie Wirtschafter, “The internationalization of organized crime in Brazil,” Brookings Institution, January 24, 2024, https://www.brookings.edu/articles/the-internationalization-of-organized-crime-in-brazil/.

[9] Terrence McCoy, “The prosecutor marked to die by South America’s most dangerous gang,” The Washington Post, February 24, 2025, https://www.washingtonpost.com/world/2025/02/24/brazil-drugs-gangs-pcc-gakiya/.

[10] Roberto Uchôa, “From Drug Trafficking to Faria Lima: The PCC’s Metamorphosis into a Corporate Conglomerate and the Threat to the Economy,” Small Wars Journal, August 30, 2025.

[11] Document held by C4ADS.

[12] Alfredo Henrique, “Cônsul africano “vendeu” imunidade diplomática para 4 chefões do PCC,” Metrópoles, March 20, 2025, https://www.metropoles.com/sao-paulo/consul-africano-vendeu-imunidade-diplomatica-para-4-chefoes-do-pcc.

[13] Rayssa Motta, Fausto Macedo, and Marcelo Godoy, “De Concierge do PCC a Don Corleone: veja quem são os 14 denunciados por rede do tráfico com a mafia,” Estadão 150, March 12, 2025, https://www.estadao.com.br/politica/blog-do-fausto-macedo/de-concierge-do-pcc-a-don-corleone-veja-quem-sao-os-14-denunciados-por-rede-do-trafico-com-a-mafia.

[14] Government of Brazil, “PF combate crimes de associação criminosa em São Paulo,” Ministry of Justice and Public Security, May 16, 2025, https://www.gov.br/pf/pt-br/assuntos/noticias/2024/05/pf-combate-crimes-de-associacao-criminosa-em-sao-paulo.

[15] Tribunal Regional Federal da 3ª Região, https://pje1g.trf3.jus.br/pje/ConsultaPublica/DetalheProcessoConsultaPublica/documentoSemLoginHTML.seam?ca=d21d77a88a8d4a0a8c7e0ffde95c113228cba321c62831ba07eb2e8607b4f530302fd14fdab67d5ba7da9c603e4aaeebdebd1858e2c82ced&idProcessoDoc=337507281, accessed October 01, 2025.

[16] “MPF/RN denuncia envolvidos na Operação Pomar,” JusBrasil, https://www.jusbrasil.com.br/noticias/mpf-rn-denuncia-envolvidos-na-operacao-pomar/192612654, accessed October 01, 2025.

[17] “Torino, traffico di droga tra Italia e Brasile: 23 arresti nell’«Operazione Samba». I legami con l’Ndrangheta piemontese,” Cronaca, December 10, 2024, https://torino.corriere.it/notizie/cronaca/24_dicembre_10/torino-la-procura-coordina-l-operazione-samba-tra-italia-e-brasile-23-arresti-i-legami-con-l-ndrangheta-piemontese-899e8449-3cff-42d8-b852-41102c9d2xlk.shtml.

[18] Government of Brazil, “Operação Mafiusi – Receita Federal e Polícia Federal deflagram operação para combater tráfico internacional de entorpecentes e lavagem de dinheiro,” Ministry of Finance, December 10, 2024, https://www.gov.br/receitafederal/pt-br/assuntos/noticias/2024/dezembro/operacao-mafiuse-receita-federal-e-policia-federal-deflagram-operacao-para-combater-trafico-internacional-de-entorpecentes-e-lavagem-de-dinheiro.

[19] Document held by C4ADS.

[20] Alfredo Henrique, “Cônsul africano ‘vendeu’ imunidade diplomática para 4 chefões do PCC,” Metrópoles, March 20, 2025, https://www.metropoles.com/sao-paulo/consul-africano-vendeu-imunidade-diplomatica-para-4-chefoes-do-pcc.

[21] Henrique, “Cônsul africano ‘vendeu’ imunidade diplomática para 4 chefões do PCC,” Metrópoles, March 20, 2025.

[22] “Electronic Articles of Incorporation for Bozhnaj Group Corporation,” Florida Secretary of State, August 30, 2023, https://search.sunbiz.org/Inquiry/CorporationSearch/ConvertTiffToPDF?storagePath=COR%5C2023%5C0905%5C20906972.tif&documentNumber=P23000063370.

[23] Bozhanaj Group Corporation, sunbiz.org, Division of Corporations (an official State of Florida website), https://search.sunbiz.org/Inquiry/CorporationSearch/SearchResultDetail?inquirytype=EntityName&directionType=ForwardList&searchNameOrder=BOZHANAJGROUP%20P230000633700&aggregateId=domp-p23000063370-61c8fa01-b6f2-4e81-8191-f40cd8a1dfac&searchTerm=BOZA%20CORPORATION.&listNameOrder=BOZHANAJGROUP%20P230000633700, accessed October 01, 2025.

[24] “2024 Florida Profit Corporation Annual Report, Bozhanaj Group Corporation,” Florida Secretary of State, May 08, 2024, https://search.sunbiz.org/Inquiry/CorporationSearch/GetDocument?aggregateId=domp-p23000063370-61c8fa01-b6f2-4e81-8191-f40cd8a1dfac&transactionId=p23000063370-61b4f68e-e616-4266-a854-8c5e079818ea&formatType=PDF.

[25] “Florida Limited Liability Company, New Alliance Export Trading LLC,” sunbiz.org, Division of Corporations (an official State of Florida website), October 15, 2015, https://search.sunbiz.org/Inquiry/corporationsearch/SearchResultDetail?inquirytype=EntityName&directionType=Initial&searchNameOrder=NEWALLIANCEEXPORTTRADING%20L150001757320&aggregateId=flal-l15000175732-e25ff624-1b5a-4088-90ba-53c83a46bfb4&searchTerm=NEW%20ALLIANCE%20EXPORT%20TRADING%20LLC&listNameOrder=NEWALLIANCEEXPORTTRADING%20L150001757320.

[26] “Florida Limited Liability Company, XOSSI International Freight LLC,” sunbiz.org, Division of Corporations (an official State of Florida website), February 14, 2017, https://search.sunbiz.org/Inquiry/CorporationSearch/SearchResultDetail?inquirytype=OfficerRegisteredAgentName&directionType=Initial&searchNameOrder=ATPLUSOFMIAMIINC%20L170000361830&aggregateId=flal-l17000036183-efdcdb36-aa5d-4e92-8e63-24d7da836d39&searchTerm=Atplus%20Of%20Miami%20Inc&listNameOrder=ATPLUSOFMIAMIINC%20L100000623510.

[27] “2025 Florida Limited Liability Company Reinstatement, XOSSI International Freight LLC,” Florida Secretary of State, January 29, 2025, https://search.sunbiz.org/Inquiry/CorporationSearch/GetDocument?aggregateId=domp-p23000063370-61c8fa01-b6f2-4e81-8191-f40cd8a1dfac&transactionId=p23000063370-492736e9-1fe1-40d1-897f-9c500468e901&formatType=PDF; and “2025 Florida Limited Liability Company Reinstatement, New Alliance Export Trading LLC,” Florida Secretary of State, April 15, 2025, https://search.sunbiz.org/Inquiry/CorporationSearch/GetDocument?aggregateId=flal-l15000175732-e25ff624-1b5a-4088-90ba-53c83a46bfb4&transactionId=l15000175732-re-d75aabf4-902e-49b0-a381-86834a0d04b2&formatType=PDF.

[28] “Tribunal Regional Federal da 3ª Região, Processo Judicial Eletrônico – 1° Grau,” https://pje1g.trf3.jus.br/pje/ConsultaPublica/DetalheProcessoConsultaPublica/documentoSemLoginHTML.seam?ca=d21d77a88a8d4a0a8c7e0ffde95c113228cba321c62831ba07eb2e8607b4f530302fd14fdab67d5ba7da9c603e4aaeebdebd1858e2c82ced&idProcessoDoc=337507281, accessed October 01, 2025.

[29] Marcelo Godoy, “PCC usa doleiros e já fatura mais de R$400 milhões,” Estadão, June 03, 2018, https://brasil.estadao.com.br/noticias/geral,pcc-usa-doleiros-e-ja-fatura-mais-de-r400-milhoes,70002335331; and Afonso Benites, “PCC movimenta mais de 100 milhões de reais nos EUA e na China,” El Pais, January 17, 2015, https://brasil.elpais.com/brasil/2015/01/16/politica/1421442251_840140.html.

[30] Rogério Pagnan, “Two Bosses of the Criminal Organization PCC Control São Paulo Drug Trade from Abroad,” Folha de S. Paulo, July 17, 2014, https://www1.folha.uol.com.br/internacional/en/saopaulo/2014/07/1487200-two-bosses-of-the-criminal-organization-pcc-control-sao-paulo-drug-trade-from-abroad.shtml; “Fuminho: One of Brazil’s most wanted criminals arrested in Mozambique,” BBC, April 14, 2020, https://www.bbc.com/news/world-africa-52288303; Document held by C4ADS; and Marcelo Godoy, “O 1º Brasileiro Chefe de um cartel de drogas,” Estadão 150, June 03, 2018, https://www.estadao.com.br/brasil/o-1-brasileiro-chefe-de-um-cartel-de-drogas/.

[31] “Czl Storage Logistica,” Econodata, https://www.econodata.com.br/consulta-empresa/10730367000114-czl-storage-armazenagem-e-logistica-ltda, accessed October 01, 2025; and “Dannenberg Importer and Exporter of Machinery and Textile Products Ltd.,” Econodata, https://www.econodata.com.br/consulta-empresa/67264820000161-dannenberg-importadora-e-exportadora-de-maquinas-e-produtos-texteis-ltda, accessed October 20, 2025.

[32] “Offshore Leaks Database/Data from Panama Papers—Mossack Fonseca,” International Consortium of Investigative Journalists, https://offshoreleaks.icij.org/nodes/12197351, accessed October 01, 2025.

[33] “CCDIBC Leads Business Delegation on Exchange Visit to China Entry-Exit Inspection and Quarantine Association,” CCDIBC,  https://brasilchina.org.br/ccdibc-lidera-delegacao-empresarial-em-visita-de-intercambio-a-associacao-chinesa-de-inspecao-e-quarentena-de-entrada-e-saida/, accessed October 20, 2025; and ““Brazil-China Connection Meeting for Transforming Results in Medical Technology” Successfully Held in Beijing,” https://brasilchina.org.br/evento-de-conexao-da-ccdibc-e-realizado-com-sucesso-em-pequim/, accessed October 20, 2025.  

[34] “Sobre,” Câmara de Comércio de Desenvolvimento Internacional Brasil-China, https://brasilchina.org.br/sobre/.

[35] “Sobre,” Câmara de Comércio de Desenvolvimento Internacional Brasil-China.

[36] Fabio Hu, Facebook photo post, August 28, 2025, https://www.facebook.com/photo/?fbid=24458898820428964&set=pcb.24458900810428765.

[37] “Presidente Fábio Hu é condecorado com a Medalha de Herói da Revolução Constitucionalista de São Paulo,” Câmara de Comércio de Desenvolvimento Internacional Brasil-China, July 09, 2025, https://brasilchina.org.br/presidente-fabio-hu-e-condecorado-com-a-medalha-de-heroi-da-revolucao-constitucionalista-de-sao-paulo/.

[38] “Presidente Fábio Hu é condecorado com a Medalha de Herói da Revolução Constitucionalista de São Paulo,” Câmara de Comércio de Desenvolvimento Internacional Brasil-China.

[39] Alfredo Henrique, “Banco do crime” do PCC movimentou R$ 8 bi para financiar campanhas, Metrópoles, September 01, 2024, https://www.metropoles.com/sao-paulo/banco-do-crime-do-pcc-movimentou-r-8-bi-para-financiar-campanhas.

[40] Alfredo Henrique, “Banco do crime” do PCC movimentou R$ 8 bi para financiar campanhas, Metrópoles, September 01, 2024; and “Currency Converter” as of January 9, 2024, https://wise.com/us/currency-converter/brl-to-usd-rate/history/31-01-2024.

[41] “Understand what changes in fintechs with new Recipe rule,” Regional Accounting Council of the State of São Paulo (CRCSP), September 01, 2025, https://online.crcsp.org.br/portal/noticias/noticia.asp?c=9675.

[42] Marina Cavalari, “Historic PCC Bust Spurs Brazil Crackdown on Digital Money Laundering,” InSight Crime, September 11, 2025, https://insightcrime.org/news/historic-pcc-bust-spurs-brazil-crackdown-on-digital-money-laundering/.

[43] “Florida Limited Liability Company, Las Americas USA LLC,” sunbiz.org, Division of Corporations (an official State of Florida website), August 17, 2017, https://search.sunbiz.org/Inquiry/CorporationSearch/SearchResultDetail?inquirytype=EntityName&directionType=ForwardList&searchNameOrder=LASAMERICASWALLETPAYMENTS%20L170001761790&aggregateId=flal-l17000176179-b84ca5c1-4805-4fe2-9ee2-0e0a4ac42f7d&searchTerm=a&listNameOrder=LASAMERICASTRAVELORGANIZATION%20V517150.

[44] “Florida Limited Liability Company, Unique Business USA LLC,” sunbiz.org, Division of Corporations (an official State of Florida website), October 13, 2017, https://search.sunbiz.org/Inquiry/CorporationSearch/SearchResultDetail?inquirytype=EntityName&directionType=ForwardList&searchNameOrder=UNIQUEBUSINESSUSA%20L170002125190&aggregateId=flal-l17000212519-85bc9971-31f2-4f25-8504-8952dd1530b5&searchTerm=a&listNameOrder=UNIQUEBUSINESSSERVICES%20P950000971440.

[45] Las Americas USA LLC was originally listed as Las Americas Wallet Payments LLC in September 2017. See “Florida Limited Liability Company, Las Americas USA LLC,” sunbiz.org, Division of Corporations (an official State of Florida website), August 17, 2017, https://search.sunbiz.org/Inquiry/CorporationSearch/SearchResultDetail?inquirytype=EntityName&directionType=ForwardList&searchNameOrder=LASAMERICASWALLETPAYMENTS%20L170001761790&aggregateId=flal-l17000176179-b84ca5c1-4805-4fe2-9ee2-0e0a4ac42f7d&searchTerm=a&listNameOrder=LASAMERICASTRAVELORGANIZATION%20V517150.

[46]  “Florida Limited Liability Company, Las Americas USA LLC,” sunbiz.org, Division of Corporations (an official State of Florida website), August 17, 2017.

[47] “Las Americas Integracao de Pagamentos Online ltda.,” Econodata, https://www.econodata.com.br/consulta-empresa/20498423000190-las-americas-integracao-de-pagamentos-online-ltda, accessed October 20, 2025.

[48] “Rejected Filing, Vulter Bridge International LLC,” sunbiz.org, Division of Corporations (an official State of Florida website), January 10, 2020, https://search.sunbiz.org/Inquiry/CorporationSearch/SearchResultDetail?inquirytype=EntityName&directionType=Initial&searchNameOrder=VULTERBRIDGEINTERNATIONAL%20W200000023770&aggregateId=reject-w20000002377-a11d636f-d998-44d6-830f-4f1b3825b21e&searchTerm=%22VULTER%20BRIDGE%20INTERNATIONAL%20LLC%22&listNameOrder=VULTERBRIDGEINTERNATIONAL%20W200000023770.

[49] “Brazil’s biggest drug gang investigated for fintech schemes,” Bloomberg, December 03, 2024, https://www.bloomberg.com/news/features/2024-12-03/brazil-s-biggest-drug-gang-investigated-for-fintech-schemes; and Alfredo Henrique, “‘Banco do crime’ do PCC movimentou R$ 8 bi para financiar campanhas,” Metrópoles, January 09, 2024,https://www.metropoles.com/sao-paulo/banco-do-crime-do-pcc-movimentou-r-8-bi-para-financiar-campanhas.

[50] Marcelo Godoy and Heitor Mazzoco, “PCC tenta se infiltrar nas eleições municipais de 2024, aponta investigação,” Estadão 150, May 20, 2025, https://www.estadao.com.br/politica/pcc-tenta-se-infiltrar-nas-eleicoes-municipais-de-2024-aponta-investigacao/.

[51] Godoy and Mazzoco, “PCC tenta se infiltrar nas eleições municipais de 2024, aponta investigação.”

[52] “Brazil’s biggest drug gang investigated for fintech schemes,” Bloomberg, December 03, 2024.

[53] Divulgação de Candidaturas e Contas Eleitorais: João Gabriel De Mello Yamawaki, August 02, 2017, https://divulgacandcontas.tse.jus.br/divulga/#/candidato/NORTE/TO/14431/125/2004/73296.

[54] Marcelo Godoy, “Máfia italiana usa ‘sistema bancário’ chinês na Europa para pagar compra de drogas do PCC,”Estadão 150, June 02, 2025, https://www.estadao.com.br/politica/marcelo-godoy/o-sistema-bancario-chines-usado-na-europa-para-pagar-a-droga-do-pcc-e-outras-revelacoes-da-mafia/.

[55] Isadora Aires, “PF prende 9 pessoas em operação contra a máfia italiana,” CNN Brazil, December 10, 2024, https://www.cnnbrasil.com.br/nacional/pf-prende-9-pessoas-em-operacao-contra-a-mafia-italiana/.

[56] “Cocaine connections: Links between the Western Balkans and South America,” Global Initiative Against Transnational Organized Crime, April 01, 2025, https://globalinitiative.net/analysis/cocaine-connections-links-between-the-western-balkans-and-south-america/.

[57] “Cómo opera la mafia albanesa para traficar cocaína desde Ecuador hacia Europa,” Infobae, June 21, 2025, https://www.infobae.com/america/america-latina/2025/06/21/como-opera-la-mafia-albanesa-para-traficar-cocaina-desde-ecuador-hacia-europa/.