(Except shown below. To read full report, go to: https://mightyearth.org/article/nyse-warned-of-violating-us-anti-money-laundering-laws-if-it-lists-jbs-shares/)

Reported by Sydney Jones

In a new legal Notice, Mighty Earth has warned the board of the New York Stock Exchange (NYSE), that it risks knowingly violating US Anti-Money Laundering (AML) laws if it allows Brazilian meat giant JBS to list its shares on the NYSE. Given the long history of criminal activity in JBS’s supply chain, any listing would “facilitate the acquisition, distribution, conversion, use or control of the proceeds of crime to shareholders, namely profits derived from cattle grazed on illegally deforested land.” The Notice catalogues extensive evidence of JBS benefitting from persistent criminal conduct within its beef supply chains in Brazil, namely illegal deforestation.

US Lacey Act

The Lacey Act in the US targets not only the final act of export, but every alleged illegal act in the supply chain, including on the ground in the producing country, in this case Brazil. The Act determines that it is a federal offense to import to the US or trade goods derived from wildlife or plant-related activity that violates a foreign law protecting natural resources, such as Brazilian environmental laws relating to illegal deforestation. If it is found that JBS derives revenue from illegally deforested land and that deforestation is criminal under foreign law this risks criminal conduct under the Lacey Act and the AML legal framework.

According to new analysis by the Environmental Investigation Agency U.S from May 2024 – April 2025, JBS S.A shipped beef products from Brazil to the United States worth roughly $767 million, highlighting the possible connection between the benefit from criminal conduct and the US jurisdiction.

JBS admission of illegal risk

In its F-4 filing to the US Securities and Exchange Commission (SEC) on 11 April 2025, JBS acknowledged that “there can be no assurance that available monitoring procedures can ensure that the origin of any head of cattle was in full compliance with applicable laws, regulations or our Responsible Procurement Policy (RPP.)”  This highlights that JBS knows, or at least suspects, that its products are tainted by criminality. In January of this year, JBS’s Global Chief Sustainability Officer Jason Weller admitted that JBS had “zero operational, contractual or legal control of its supply chain.”