Brazil
Overview
Brazil’s AML/CFT framework is anchored in Law 9,613/1998 as materially amended by Law 12,683/2012, with sector-specific implementing rules such as BCB Circular 3,978/2020. Law 13,810/2019 addresses targeted asset freezing, while Law 14,478/2022 and BCB rules create the current virtual-assets perimeter. BCB Resolution 588/2026 amends Circular 3,978 from 1 October 2026 and adds a specific-reporting trigger for virtual-asset transfers to or from self-hosted wallets at or above US$10,000 equivalent.
CDD beneficial-owner obligations are embedded in sector AML rules. Corporate transparency is reinforced through Receita Federal beneficial-owner reporting, with e-BEF mandatory for covered entities from January 2026.
Obliged persons file suspicious transaction/activity communications with COAF under Law 9,613 and sector rules. Monitoring, CDD and recordkeeping requirements are set by the competent sector supervisor. For BCB-authorised institutions within Circular 3,978, Resolution 588/2026 adds from 1 October 2026 a specific-operation reporting trigger for virtual-asset transfers to or from self-hosted wallets at or above US$10,000 equivalent.
Compliance Calendar6
Requirement
Comunicação de Não Ocorrência (CNO) — selected COAF-regulated sectors
Authority / Report toCOAF
Deadline / triggerFor the 2025 reference period, by 31 Jan 2026. Future annual dates must be checked against that year’s notice.
Requirement
- Subject scope
- Directly COAF-regulated factoring and jewellery/precious-stones/metals sectors where no reportable events occurred in the reference year.
- Trigger
- No reportable proposals, transactions or operations during the annual period.
- Filing channel
- Siscoaf.
Impact
- Consequences of non-compliance
- Failure to submit can result in an administrative sanction/fine after proceedings.
- Enforcement authority
- COAF
- Operational impact
- Do not roll this date forward mechanically; ingest each annual notice.
Requirement
Insurance
SUSEP Resolution No. 99/2026 AML/CFT/CPF framework transition
Authority / Report toSuperintendência de Seguros Privados (SUSEP)
Deadline / triggerImplement the updated framework by 1 January 2027, when Resolution No. 99/2026 enters into force and Circular No. 612/2020 is revoked.
Requirement
- Sector scope
- Insurance
- Subject scope
- SUSEP-supervised insurers, capitalisation companies, open pension entities, reinsurers, reinsurance brokers, insurance brokers and the additional supervised categories expressly brought into scope by Resolution No. 99/2026.
- Trigger
- Publication of Resolution No. 99/2026 replacing Circular No. 612/2020.
- Filing channel
- No discrete filing identified in the official summary; implementation is through internal AML/CFT/CPF policies, risk assessment, CDD and control procedures subject to SUSEP supervision.
Impact
- Consequences of non-compliance
- Non-compliance may be addressed through SUSEP supervisory and administrative enforcement under the applicable sector framework.
- Enforcement authority
- Superintendência de Seguros Privados (SUSEP)
- Operational impact
- Complete gap analysis and update AML/CFT/CPF governance, internal risk assessment, CDD tiers, PEP/beneficial-owner procedures and higher-risk controls before commencement.
Requirement
Banking / Credit InstitutionsPayments / EMI / Money TransferCrypto / VASP / CASP
Communication of qualifying self-hosted virtual-asset transfers
Authority / Report toCOAF
Deadline / triggerBy the next business day under the Circular’s communication-of-specific-operations rule.
Requirement
- Sector scope
- Banking / Credit InstitutionsPayments / EMI / Money TransferCrypto / VASP / CASP
- Subject scope
- BCB-authorised institutions subject to Circular 3,978/2020 as amended by BCB Resolution 588/2026.
- Trigger
- Transfer of virtual assets to or from a self-hosted wallet with value equal to or above the equivalent of US$10,000.
- Filing channel
- Applicable COAF/Siscoaf reporting channel.
Impact
- Consequences of non-compliance
- Failure to make a prescribed specific-operation communication can lead to BCB administrative enforcement under the applicable AML/CFT framework.
- Enforcement authority
- Banco Central do Brasil / COAF within their competencies
- Operational impact
- Add the US$10,000-equivalent self-hosted-wallet threshold to specific-operation monitoring and reporting logic before 1 October 2026.
Requirement
Banking / Credit InstitutionsPayments / EMI / Money Transfer
Communication of reportable cash operations
Authority / Report toCOAF
Deadline / triggerBy the next business day under the Circular’s cash-communication rule.
Requirement
- Sector scope
- Banking / Credit InstitutionsPayments / EMI / Money Transfer
- Subject scope
- BCB-authorised institutions subject to Circular 3,978.
- Trigger
- Cash deposit/contribution or withdrawal equal to or above R$50,000 and other art. 49 cash events.
- Filing channel
- Applicable COAF electronic channel.
- Legal basis
Impact
- Consequences of non-compliance
- Missing prescribed cash communications can result in BCB enforcement.
- Enforcement authority
- Banco Central do Brasil
- Operational impact
- Identify qualifying physical-cash events separately from suspicion-based reporting.
Requirement
Banking / Credit InstitutionsPayments / EMI / Money Transfer
Communication of suspicious operation or situation to COAF
Authority / Report toCOAF
Deadline / triggerBy the next business day after the decision to communicate.
Requirement
- Sector scope
- Banking / Credit InstitutionsPayments / EMI / Money Transfer
- Subject scope
- Institutions authorised by Banco Central do Brasil under Circular 3,978/2020.
- Trigger
- Decision, after monitoring/analysis, that an operation or situation should be communicated as suspicious.
- Filing channel
- Applicable COAF/Siscoaf reporting channel.
Impact
- Consequences of non-compliance
- Failure or late communication can lead to BCB administrative enforcement; sanctions depend on the breach.
- Enforcement authority
- Banco Central do Brasil / COAF within their competencies
- Operational impact
- Evidence the date of the communication decision because it starts the filing clock.
Requirement
Banking / Credit InstitutionsPayments / EMI / Money Transfer
Internal ML/TF risk assessment and AML controls
Authority / Report toBanco Central do Brasil
Deadline / triggerOngoing; internal risk assessment, policy, monitoring, CDD, training and effectiveness controls must be maintained.
Requirement
- Sector scope
- Banking / Credit InstitutionsPayments / EMI / Money Transfer
- Subject scope
- Institutions authorised by Banco Central do Brasil within Circular 3,978.
- Trigger
- Continuous operation and changes in risk profile/products/customers/channels.
- Filing channel
- Internal governance and supervisory evidence.
Impact
- Consequences of non-compliance
- Deficiencies can lead to supervisory remediation and administrative sanction proceedings.
- Enforcement authority
- Banco Central do Brasil
- Operational impact
- Maintain documented risk categories, governance approval and effectiveness testing.
Authorities & FIU6
FATF Assessment
Measures how fully the jurisdiction has implemented FATF’s technical requirements. It does not measure practical effectiveness.
Measures whether the AML/CFT system achieves its intended results in practice. Follow-up reports do not normally replace these ratings.
Explore 40 FATF RecommendationsSee every Technical Compliance rating and what it means.+
Explore 11 Immediate OutcomesSee how FATF rates whether the AML/CFT system works in practice.+
Regulatory Timeline42
SUSEP published Resolution No. 99/2026 on 1 October 2026. The rule replaces Circular No. 612/2020, expands the supervised perimeter, expressly incorporates proliferation-financing prevention, and formalises simplified, standard and enhanced due-diligence levels under the risk-based approach. It enters into force on 1 January 2027.
Banco Central do Brasil amended Circular No. 3,978/2020 to restate specific-operation reporting thresholds and add transfers of virtual assets to or from self-hosted wallets of at least US$10,000 equivalent. The amendment was published in the DOU on 25 September 2026 and enters into force on 1 October 2026.
Coaf Normative Instruction No. 1 of 16 July 2026, published in the Federal Official Gazette on 28 July and in force since 3 August 2026, supplements Coaf Resolutions 36/2021 and 41/2022. It specifies reinforced CDD for persons, financial institutions and beneficial ownership structures connected with FATF-designated high-risk or deficient jurisdictions, including source-of-funds evidence, more intensive monitoring, documented decisions and higher-level authorization.
Receita Federal centralises beneficial-owner information in the e-BEF digital form for entities subject to the filing obligation.
Banco Central adopts detailed rules for virtual-asset service providers, including operational and transfer-related requirements under Brazil’s virtual-assets framework.
FATF revised Recommendation 16 to standardise payment information and strengthen fraud/error controls in cross-border payments.
Current relationship. Direct FATF membership and any listed regional assessment network participation are current profile relationships only. The GLOBAL milestone does not prove membership or domestic implementation on the event date; those remain LOCAL/STATUS evidence.
FATF Global Network ↗FATF amended Recommendation 1 and related interpretive material to strengthen proportionality and simplified measures under the risk-based approach.
Current relationship. Direct FATF membership and any listed regional assessment network participation are current profile relationships only. The GLOBAL milestone does not prove membership or domestic implementation on the event date; those remain LOCAL/STATUS evidence.
FATF Global Network ↗FATF revised Recommendations 4, 30, 31 and 38 and related interpretive material to make asset recovery a stronger operational priority, expand tools to trace and confiscate criminal property and improve domestic and international cooperation.
Current relationship. Direct FATF membership and any listed regional assessment network participation are current profile relationships only. The GLOBAL milestone does not prove membership or domestic implementation on the event date; those remain LOCAL/STATUS evidence.
FATF Global Network ↗At its February 2023 Plenary FATF revised Recommendation 25 and its Interpretive Note to strengthen transparency and beneficial-ownership requirements for trusts and similar legal arrangements, complementing the 2022 strengthening of Recommendation 24 for legal persons.
Current relationship. Direct FATF membership and any listed regional assessment network participation are current profile relationships only. The GLOBAL milestone does not prove membership or domestic implementation on the event date; those remain LOCAL/STATUS evidence.
FATF Global Network ↗The law establishes principles for virtual-asset services and the regulatory perimeter for virtual-asset service providers, while preserving CVM competence for securities tokens.
FATF strengthened Recommendation 24 on beneficial ownership transparency for legal persons.
Current relationship. Direct FATF membership and any listed regional assessment network participation are current profile relationships only. The GLOBAL milestone does not prove membership or domestic implementation on the event date; those remain LOCAL/STATUS evidence.
FATF Global Network ↗FATF amended Recommendations 1 and 2 and their Interpretive Notes so countries and covered private-sector entities must identify, assess and mitigate risks of breaches, non-implementation or evasion of proliferation-related targeted financial sanctions.
Current relationship. Direct FATF membership and any listed regional assessment network participation are current profile relationships only. The GLOBAL milestone does not prove membership or domestic implementation on the event date; those remain LOCAL/STATUS evidence.
FATF Global Network ↗The Basel Committee revised its ML/TF risk-management guidelines to add principles for information exchange and cooperation between prudential and AML/CFT supervisors in authorisation, ongoing supervision and enforcement.
A Basel supervisory publication does not become domestic law merely because it is GLOBAL. National adoption, supervisory use or incorporation must be evidenced by a LOCAL milestone or source.
Basel Committee on Banking Supervision ↗Banco Central do Brasil Circular 3,978 established revised AML/CFT policies, procedures and internal controls for supervised institutions. Its commencement was postponed to 1 October 2020.
FATF adopted detailed implementation requirements for virtual assets and VASPs in June 2019, including the application of wire-transfer information requirements commonly described as the Travel Rule. This operationalised the virtual-asset perimeter introduced through the 2018 Recommendation 15 revision.
Current relationship. Direct FATF membership and any listed regional assessment network participation are current profile relationships only. The GLOBAL milestone does not prove membership or domestic implementation on the event date; those remain LOCAL/STATUS evidence.
FATF Global Network ↗Brazil establishes statutory procedures for immediate asset unavailability linked to UN Security Council sanctions designations and related TFS implementation.
In October 2018 FATF revised Recommendation 15 and added the definitions of virtual asset and virtual asset service provider, formally bringing virtual-asset activity into the global AML/CFT standards architecture. Detailed implementation requirements followed in 2019.
Current relationship. Direct FATF membership and any listed regional assessment network participation are current profile relationships only. The GLOBAL milestone does not prove membership or domestic implementation on the event date; those remain LOCAL/STATUS evidence.
FATF Global Network ↗The Basel Committee issued Sound management of risks related to money laundering and financing of terrorism, superseding its 2001 CDD and 2004 consolidated KYC papers and integrating ML/TF risk management with prudential supervisory expectations.
A Basel supervisory publication does not become domestic law merely because it is GLOBAL. National adoption, supervisory use or incorporation must be evidenced by a LOCAL milestone or source.
Basel Committee on Banking Supervision ↗Brazil amended Law 9,613 to strengthen the prosecution and prevention of money laundering, including broadening the predicate-offence approach.
FATF adopted a consolidated revised set of 40 Recommendations integrating AML, CFT and proliferation-financing safeguards.
Current relationship. Direct FATF membership and any listed regional assessment network participation are current profile relationships only. The GLOBAL milestone does not prove membership or domestic implementation on the event date; those remain LOCAL/STATUS evidence.
FATF Global Network ↗Resolution 1737 imposed binding measures concerning Iran’s proliferation-sensitive nuclear activities, including an asset freeze on designated individuals and entities. Together with the DPRK regime, it forms a foundational UN counter-proliferation targeted-financial-sanctions architecture.
UN Members agree to accept and carry out Security Council decisions. This current Charter relationship is not proof of the jurisdiction’s domestic implementation, nor a claim about its membership status on the historical event date.
UN Charter · Article 25 ↗Following the DPRK nuclear test, Resolution 1718 imposed binding sanctions including an asset freeze on designated persons and entities connected to the nuclear programme. It became a central UN targeted-financial-sanctions pillar for counter-proliferation financing.
UN Members agree to accept and carry out Security Council decisions. This current Charter relationship is not proof of the jurisdiction’s domestic implementation, nor a claim about its membership status on the historical event date.
UN Charter · Article 25 ↗FATF added a ninth Special Recommendation addressing cash couriers and cross-border movement of currency.
Current relationship. Direct FATF membership and any listed regional assessment network participation are current profile relationships only. The GLOBAL milestone does not prove membership or domestic implementation on the event date; those remain LOCAL/STATUS evidence.
FATF Global Network ↗Resolution 1540 requires all States to adopt and enforce laws and domestic controls to prevent non-State actors from acquiring or using weapons of mass destruction and related materials. It forms a binding global legal pillar of the proliferation-financing control environment later reflected in FATF CPF standards.
UN Members agree to accept and carry out Security Council decisions. This current Charter relationship is not proof of the jurisdiction’s domestic implementation, nor a claim about its membership status on the historical event date.
UN Charter · Article 25 ↗The UN General Assembly adopted the United Nations Convention against Corruption on 31 October 2003. UNCAC addresses prevention of money laundering, laundering of corruption proceeds, confiscation and a dedicated asset-recovery framework; the Convention entered into force globally on 14 December 2005.
Current UN depositary relationship to 2003 UN Convention against Corruption. This is not a claim that the jurisdiction was already a Party on the GLOBAL event date; the national accession/ratification date is a separate LOCAL/STATUS fact.
UN Treaty Collection ↗FATF comprehensively revised its AML/CFT Recommendations, strengthening preventive measures and extending coverage.
Current relationship. Direct FATF membership and any listed regional assessment network participation are current profile relationships only. The GLOBAL milestone does not prove membership or domestic implementation on the event date; those remain LOCAL/STATUS evidence.
FATF Global Network ↗The Basel Committee issued Customer due diligence for banks, setting minimum supervisory expectations for customer acceptance, identification, ongoing monitoring and risk management. It became an influential global banking KYC/CDD benchmark and was later reflected in FATF standards.
A Basel supervisory publication does not become domestic law merely because it is GLOBAL. National adoption, supervisory use or incorporation must be evidenced by a LOCAL milestone or source.
Basel Committee on Banking Supervision ↗FATF expanded its standards to terrorist financing through eight Special Recommendations.
Current relationship. Direct FATF membership and any listed regional assessment network participation are current profile relationships only. The GLOBAL milestone does not prove membership or domestic implementation on the event date; those remain LOCAL/STATUS evidence.
FATF Global Network ↗Resolution 1373 requires all States to prevent and suppress terrorist financing, criminalise the provision or collection of funds for terrorist acts, freeze terrorist assets without delay and prohibit making funds or financial services available to terrorists and related entities.
UN Members agree to accept and carry out Security Council decisions. This current Charter relationship is not proof of the jurisdiction’s domestic implementation, nor a claim about its membership status on the historical event date.
UN Charter · Article 25 ↗GAFILAT records Brazil among the nine governments that signed the constitutive Memorandum of Understanding on 8 December 2000.
The Palermo Convention was adopted on 15 November 2000 and broadened the international money-laundering framework beyond drug proceeds through criminalisation and preventive measures tied to transnational organised crime. It entered into force globally on 29 September 2003.
Current UN depositary relationship to 2000 Palermo Convention. This is not a claim that the jurisdiction was already a Party on the GLOBAL event date; the national accession/ratification date is a separate LOCAL/STATUS fact.
UN Treaty Collection ↗FATF records Brazil as a member since 2000.
The UN General Assembly adopted the International Convention for the Suppression of the Financing of Terrorism on 9 December 1999, creating the treaty framework for criminalising terrorist financing and international cooperation. It entered into force globally on 10 April 2002.
Current UN depositary relationship to 1999 Terrorist Financing Convention. This is not a claim that the jurisdiction was already a Party on the GLOBAL event date; the national accession/ratification date is a separate LOCAL/STATUS fact.
UN Treaty Collection ↗Resolution 1267 imposed an assets freeze and other targeted sanctions in the Taliban context and created the Security Council committee that became the foundation of the UN 1267 sanctions architecture. It is a key global precursor to modern terrorist-financing targeted financial sanctions.
UN Members agree to accept and carry out Security Council decisions. This current Charter relationship is not proof of the jurisdiction’s domestic implementation, nor a claim about its membership status on the historical event date.
UN Charter · Article 25 ↗The Egmont Group's official Member FIU Information register records Brazil's FIU admission date as 1999-05-28.
Brazil enacted its foundational money-laundering law and created COAF.
FATF revised the Forty Recommendations to reflect evolving money-laundering methods and countermeasures.
Current relationship. Direct FATF membership and any listed regional assessment network participation are current profile relationships only. The GLOBAL milestone does not prove membership or domestic implementation on the event date; those remain LOCAL/STATUS evidence.
FATF Global Network ↗Representatives of 13 financial intelligence units met in Brussels on 9 June 1995 and founded what became the Egmont Group. The milestone created the operational global network for FIU-to-FIU cooperation and exchange of financial intelligence.
Current profile relationship to the Egmont network. This does not imply membership in 1995; admission history is a separate LOCAL/STATUS fact.
Egmont Group · Member FIUs ↗FATF issued its original Forty Recommendations, establishing the first global AML standard framework.
Current relationship. Direct FATF membership and any listed regional assessment network participation are current profile relationships only. The GLOBAL milestone does not prove membership or domestic implementation on the event date; those remain LOCAL/STATUS evidence.
FATF Global Network ↗The G7 established FATF in 1989 to examine and develop measures to combat money laundering. FATF became the central global standard-setting body whose recommendations are implemented through national and regional AML/CFT frameworks.
Current relationship. Direct FATF membership and any listed regional assessment network participation are current profile relationships only. The GLOBAL milestone does not prove membership or domestic implementation on the event date; those remain LOCAL/STATUS evidence.
FATF Global Network ↗The Vienna Convention was adopted on 20 December 1988 and created the first treaty-level international obligation to criminalise laundering conduct linked to drug-trafficking proceeds, alongside confiscation and international-cooperation measures. It entered into force globally on 11 November 1990.
Current UN depositary relationship to 1988 Vienna Convention. This is not a claim that the jurisdiction was already a Party on the GLOBAL event date; the national accession/ratification date is a separate LOCAL/STATUS fact.
UN Treaty Collection ↗The Basel Committee published a Statement of Principles for banks aimed at reducing the risk that banking institutions would be used by criminals or as channels for money laundering. This helped establish the preventive and supervisory side of AML alongside the emerging criminal-law framework.
A Basel supervisory publication does not become domestic law merely because it is GLOBAL. National adoption, supervisory use or incorporation must be evidenced by a LOCAL milestone or source.
Basel Committee on Banking Supervision ↗