The U.S. Department of State announced on Aug. 13, 2025, that it has revoked or restricted visas for two Brazilian nationals alleged to have ties to the “Mais Médicos” program, a federal initiative launched in 2013 to address the shortage of medical professionals in remote areas of the country. The program deploys workers from Cuba’s overseas medical labor program, which relies on forced labor, according to the U.S. government. The sanctioned individuals include current Ministry of Health official Mozart Julio Tabosa Sales and former Pan American Health Organization official Alberto Kleiman. This action represents an expansion of U.S. visa restrictions policy and comes on the heels of a series of U.S. measures targeting Brazil, including those previously referenced in our August 4 client alert:

• Sanctions under the Global Magnitsky Human Rights Accountability Act against Justice Alexandre de Moraes in July 2025
• A 50% International Economic Emergency Powers Act (IEEPA) tariff on most Brazilian imports, effective Aug. 6, 2025, with exemptions for specific products

The U.S. government has been sharply critical of Brazil’s recent human rights record. The State Department’s 2024 Country Reports on Human Rights Practices: Brazil, issued on Aug. 12, 2025, cited restrictions on freedom of speech affecting supporters of former president Jair Bolsonaro and pointed to potential human rights issues linked to judicial orders by Brazil’s Supreme Federal Court, particularly Justice Alexandre de Moraes, that limited access to certain social media accounts. Brazilian officials have rejected the allegations.

These developments are unfolding rapidly, with new actions and statements emerging almost daily, marking one of the most significant periods of diplomatic tension between the U.S. and Brazil in recent years.

Implications for Businesses

Given the speed and scope of these developments, U.S.-based or registered companies with cross-border operations should anticipate heightened political and regulatory risk when engaging with Brazilian counterparties or government entities. The combination of targeted sanctions, tariffs, visa restrictions, and human rights –related findings are expected to:

• Increase compliance and due diligence burdens for U.S. companies operating in or sourcing from Brazil
• Affect the ability of Brazilian nationals, including public officials, to travel to the U.S. for business or official purposes
• Heighten scrutiny of joint ventures, government contracts, and supply chain relationships that involve Brazilian public entities or officials