WASHINGTON — Today, the U.S. Department of the Treasury’s Office of Foreign Assets Control (OFAC) is sanctioning the Lex Instituto de Estudos Juridicos LTDA (Lex Institute) for its support to Brazilian Supreme Federal Court (STF) justice Alexandre de Moraes (de Moraes). De Moraes was designated by OFAC on July 30, 2025, for using his position to authorize arbitrary pre-trial detentions and suppress freedom of expression in Brazil. Also designated today is Viviane Barci de Moraes (Viviane), de Moraes’ wife, who serves as the head of the Lex Institute.
“Alexandre de Moraes is responsible for an oppressive campaign of censorship, arbitrary detentions, and politicized prosecutions—including against former President Jair Bolsonaro,” said Secretary of the Treasury Scott Bessent. “Today’s action makes clear that Treasury will continue to target individuals who provide material support to de Moraes as he abuses human rights.”
Today’s action is being taken pursuant to Executive Order (E.O.) 13818, which builds upon and implements the Global Magnitsky Human Rights Accountability Act and targets perpetrators of serious human rights abuse around the world.
NETWORK SUPPORTING DE MORAES
On July 30, 2025, President Trump issued E.O. 14323, Addressing Threats to the United States by the Government of Brazil, which explains that de Moraes has abused his judicial authority to target political opponents and suppress dissent. De Moraes’ decision in the unjust conviction of former Brazilian President Jair Bolsonaro has shown his increased willingness to partake in political persecution. Today’s action focuses on those that provide a financial support network to de Moraes.
The Lex Institute acts as a holding company for de Moraes, owning his residence in addition to other residential properties. The nominal ownership of many of these properties was transferred from de Moraes and his family to the Lex Institute over a decade ago. De Moraes’ wife, Viviane, is the Managing Partner of the Lex Institute and has been the sole manager and administrator of the Lex Institute since its establishment in 2000. Together, the Lex Institute and Viviane hold the de Moraes family’s wealth.
The Lex Institute is being sanctioned pursuant to E.O. 13818 for having materially assisted, sponsored, or provided financial, material, or technological support for, or goods or services to or in support of de Moraes, a person whose property and interests in property are blocked pursuant to E.O. 13818.
Viviane is being sanctioned pursuant to E.O. 13818 for being, or having been, a leader or official of the Lex Institute, an entity whose property and interests in property are blocked pursuant to E.O. 13818 as a result of activities related to Viviane’s tenure.
GLOBAL MAGNITSKY
Building upon the Global Magnitsky Human Rights Accountability Act, E.O. 13818 was issued on December 20, 2017, in recognition that the prevalence of human rights abuse and corruption that have their source, in whole or in substantial part, outside the United States, had reached such scope and gravity as to threaten the stability of international political and economic systems. Human rights abuse and corruption undermine the values that form an essential foundation of stable, secure, and functioning societies; have devastating impacts on individuals; weaken democratic institutions; degrade the rule of law; perpetuate violent conflicts; facilitate the activities of dangerous persons; and undermine economic markets. The United States seeks to impose tangible and significant consequences on those who commit serious human rights abuse or engage in corruption, as well as to protect the financial system of the United States from abuse by these same persons.
SANCTIONS IMPLICATIONS
As a result of today’s action, all property and interests in property of the designated or blocked persons described above that are in the United States or in the possession or control of U.S. persons are blocked and must be reported to OFAC. In addition, any entities that are owned, directly or indirectly, individually or in the aggregate, 50 percent or more by one or more blocked persons are also blocked. Unless authorized by a general or specific license issued by OFAC, or exempt, OFAC’s regulations generally prohibit all transactions by U.S. persons or within (or transiting) the United States that involve any property or interests in property of blocked persons.
Violations of U.S. sanctions may result in the imposition of civil or criminal penalties on U.S. and foreign persons. OFAC may impose civil penalties for sanctions violations on a strict liability basis. OFAC’s Economic Sanctions Enforcement Guidelines provide more information regarding OFAC’s enforcement of U.S. economic sanctions. In addition, financial institutions and other persons may risk exposure to sanctions for engaging in certain transactions or activities involving designated or otherwise blocked persons. The prohibitions include the making of any contribution or provision of funds, goods, or services by, to, or for the benefit of any designated or blocked person, or the receipt of any contribution or provision of funds, goods, or services from any such person.
The power and integrity of OFAC sanctions derive not only from OFAC’s ability to designate and add persons to the Specially Designated Nationals and Blocked Persons List (SDN List), but also from its willingness to remove persons from the SDN List consistent with the law. The ultimate goal of sanctions is not to punish, but to bring about a positive change in behavior. For information concerning the process for seeking removal from an OFAC list, including the SDN List, or to submit a request, please refer to OFAC’s guidance on Filing a Petition for Removal from an OFAC List.
Click here for more information on the persons designated today.
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