BR v13.3.0

Brazil (BR) · Module Detail

Brazil: AML/CFT & Financial Crime (Sentinel.gi-fed)

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[SENTINEL-FED] Payments-context AML/CFT position only. Brazil's AML/CFT regime centres on Law 9.613/1998 (the AML Law, amended by Laws 10.701/2003, 12.683/2012, 13.974/2020), which created COAF as the financial intelligence unit (operationally autonomous, administratively linked to the BCB). BCB Circular 3.978/2020 sets the AML/CFT policy, procedures and internal-controls framework for supervised entities, including payment institutions. Brazil is a FATF and GAFILAT member; the 2023 FATF/GAFILAT mutual evaluation noted strengths and gaps (notably BO access and non-bank supervision). For payments: institutions must KYC, monitor transactions, keep records, and report suspicious activity to COAF.

Standing sub-brief · as of 23 June 2026216 words · last cycle 2026-06-23

AML/CFT & Financial Crime

This module carries the Sentinel.gi feed only and does not re-analyse illicit finance; original illicit-finance analysis is routed to the Financial Intelligence Monitor. As reported via the Sentinel feed, Brazil operates its payments-context AML/CFT regime through Law 9.613/1998, which created the COAF financial intelligence unit — operationally autonomous and administratively linked to the BCB — together with BCB Circular 3.978/2020 setting AML/CFT policy and internal-controls obligations for supervised entities including payment institutions. Brazil is a FATF/GAFILAT member. The 2023 mutual evaluation noted beneficial-ownership access and non-bank supervision gaps. Suspicious-transaction reporting is required within 24 hours, records kept for at least five years, with reporting from transactions of R$10,000. The Sentinel feed also notes crypto-Pix laundering vectors and VASP/gold AML expansion.

no periodic updates on record for this sub-brief

Sources and findings (8)
  1. T3https://fincrimecentral.com/brazil-aml-reforms-fines-financial-crime-coaf/retrieved
  2. T?FIM (sentinel.gi) per-JID baseline profile — Brazil — AML Law 9613/1998 with COAF (FIU) at its centre, coordinated via the ENCCLA inter-agency mechanism; joint FATF/GAFILAT MER (Dec 2023) found improved risk understanding and TF criminalisation but weak DNFBP supervision and unpopulated BO data. New BCB Resolutions 519-521 (Nov 2025) create a VASP licensing regime effective Feb 2026.
  3. T3FIM (sentinel.gi) regulatory_horizon_register (issue FIM-BASE-HRZ-001) — SPSAV VASP authorisation deadline for existing crypto firms
  4. T1FIM (sentinel.gi) sanctions_change_register (issue FIM-BASE-SANC-003) — Sanctions: OFAC listing
  5. T1FIM (sentinel.gi) enforcement_action_register (issue FIM-BASE-ENF-006) — Enforcement: OFAC (US Treasury) — Pixwave Solucoes de Pagamentos, Victory Trading, Wave Construcoes (Brazilian entities linked to PCC)
  6. T?FIM (sentinel.gi) gaps_register_cumulative (issue FIM-BASE-GAP-004) — Gap: capacity-deficit
  7. T?FIM (sentinel.gi) gaps_register_cumulative (issue FIM-BASE-GAP-005) — Gap: enforcement-absence
  8. T?FIM (sentinel.gi) gaps_register_cumulative (issue FIM-BASE-GAP-002) — Gap: regulatory-failure