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The production of soy is one of the most important economic activities in the Brazilian Amazon, though the expansion of this industry has come at the cost of huge swaths of forest. Since 2006, the private firms that buy and trade soybeans globally have assumed a key role in ensuring that soy producers comply with forest protection policies, including the Soy Moratorium and public policies banning the use of illegally deforested land. We used evidence from field interviews and a GIS of property boundaries and soy-production areas to describe the private sector governance process and to characterize the variety of property arrangements underlying soy production in Mato Grosso, the leading soy-producing state in the Brazilian Amazon. These increasingly complex property arrangements include ownership of multiple properties by a single producer, use of rental properties owned by others, and soy and cattle production on a single property. This complexity could create loopholes allowing soy associated with deforestation to enter the supply chain. Comprehensive soy-governance strategies that include more robust procedures for verifying the provenance of soy across all properties, that account for the entire property rather than only the area planted to soy, and that use more transparent verification systems could achieve greater reductions in deforestation.