As a publicly listed company, Taurus is one of the few manufacturers of law enforcement equipment worldwide to publish annual reports and financial statements. These provide a useful insight into the companies export practices as well as its growth internationally. Analysis of these reports and statements for the period 2012-2018 reveals that although the company exports the vast majority (91%) of its firearms to the United States , Taurus products are nonetheless present in countries around the world140. During the period analysed Taurus exported, around R$78 million reais to Latin America and the Caribbean, R$76 million reais to Asia, and R$43 million reais to the Middle East. The reports also reveal that, despite a sharp decline in sales during the middle of the past decade, exports of Taurus products nearly doubled in the period 2014 to 2018 from R$430 million to R$833 million reais141. --The cases above demonstrate not only the scope and diversity of the Brazilian trade in law enforcement and security equipment but also the failure of the companies involved to adequately regulate themselves. In order to minimise the risk of Brazilian manufactured products being used to commit human rights violations, therefore, it is essential that the export of the types of law enforcement equipment described in this report are strictly regulated. Without such regulation, Brazil will not only be failing in its international obligations but also risks undermining its regional and international reputation as a peace-builder. With this in mind, the following section examines recent changes to the regulation of the import and export of law enforcement equipment and weapons in Brazil. Recent controversies related to the company have raised serious questions about the company’s corporate governance and its compliance with business and human rights principles. In 2016, for example, federal PNEMEM prosecutors in southern Brazil charged two former executives of Forjas Taurus with shipping 8,000 handguns to Fares Mohammed Hassan Mana’a142, a known Yemeni arms trafficker. According to court documents, the handguns were initially intended for Djibouti but were redirected by Mana’a for use in Yemen, which was the subject of a UN arms embargo. During the period of its implementation, very little detailed information about the PNENEM policy or its application was publicly available. However, in 2016, following the submission of a series of FOI requests and consultations with the Foreign Ministry Central Archive, researcher David Almstadter Mattar de Magalhães was granted access to around 800 pages of documents related to the policy, including details of export requests made by companies between 2011 and 2014178. Although PENEMEM has been superseded by PNEIPRODE in 2018, these documents nevertheless provide valuable insights into the operation of Brazil’s export control regime as well as the Foreign Ministry’s decision-making processes in relation to arms exports at the beginning of the past decade. According to documents analysed by Almstadter Mattar de Magalhães, between 2011-2014 the Foreign Ministry179 received 901 requests for preliminary negotiations, of which only 35 (3.88%) ▲ Two Taurus PT 24/7 pistols advertised for sale on Telegram in Yemen. Source: United Nations Security Council, Final report of the Panel of Experts, in accordance with paragraph 6 of resolution 2456 (2019) (27 Jan 2020) S/2020/70 see: https://bit.ly/3bVRLid Several months later it was reported that in 2015 Taurus had also arranged to sell firearms to Mana’a’s son, Adeeb Mana’a. According to a UN report, the firearms were ‘very likely destined for the black market in Somalia and the wider region’, but were seized by Saudi Arabia in transit143. In its report, the UN noted that ‘had Taurus Forjas S.A exercised due diligence then they would have identified aspects of this arms purchase that were suspicious in relation to the targeted arms embargo on Yemen and could have stopped the shipment’. The UN added that ‘the modus operandi of the transfer, using his son Adeeb Mana’a and a Djibouti end user, was designed to circumvent normal security and customs controls’ . were rejected. During the same period, the foreign ministry received a total of 1012 requests for export licenses of which only 7 (0.69%) were refused. Analysis of the export requests rejected by the Foreign Ministry demonstrates that decisionmaking in relation to the export of security equipment was guided by a range of criteria, including the existence of arms embargoes, social or political unrest, as well as the possibility that the equipment transferred might be used in human rights abuses or diverted. In 2012 and 2013 for example, documents show that the Foreign Ministry vetoed requests from the company Taurus to engage in preliminary negotiations with Libya - which at the time was the subject of a UN arms embargo. In its response to the requests, the Ministry highlighted the risk that the transfer 144 52  53