title: Brazil — AML/CFT & Financial Crime (Sentinel.gi-fed) | World Payments Monitor canonical: https://payments.gi/jurisdictions/brazil/w11/ publisher: Asymmetric Intelligence ### W11 AML/CFT & Financial Crime (Sentinel.gi-fed) [Sourced from Sentinel.gi ↗](https://sentinel.gi/jurisdictions/brazil/#sec-dom-D7) Confirmed confirmed 2026-06-23 [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 2026 216 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. The regime defines the AML/CFT obligation set — KYC, monitoring and COAF STR filing — that payment institutions must operate, and the bank-versus-non-bank supervision gap identified in the 2023 evaluation is a structural payments-AML risk specific to the non-bank PI perimeter. #### Outlook The trajectory is stable but reform-directed, per the Sentinel feed. The beneficial-ownership access and non-bank supervision gaps flagged by FATF/GAFILAT in 2023 are the standing reform pressure points. Original illicit-finance typologies — including crypto-Pix vectors and PCC-related laundering — are carried into the Financial Intelligence Monitor rather than analysed here. no periodic updates on record for this sub-brief ** Sources and findings (8)** 1. T3 [https://fincrimecentral.com/brazil-aml-reforms-fines-financial-crime-coaf/](https://fincrimecentral.com/brazil-aml-reforms-fines-financial-crime-coaf/) retrieved 2026-06-23 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. T3 FIM (sentinel.gi) regulatory_horizon_register (issue FIM-BASE-HRZ-001) — SPSAV VASP authorisation deadline for existing crypto firms 4. T1 FIM (sentinel.gi) sanctions_change_register (issue FIM-BASE-SANC-003) — Sanctions: OFAC listing 5. T1 FIM (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