Brazil’s Law No. 9,613/1998 is the country’s core anti-money laundering statute. For virtual asset service providers, the operative AML profile comes from the amendments made by Law No. 14,478/2022, which added “prestadoras de serviços de ativos virtuais” to Article 9 and added “ativos virtuais” to Article 10 recordkeeping language. As of July 7, 2026, the VASP-facing AML provisions are in force, with the virtual-asset amendments effective after Law No. 14,478’s 180-day vacatio legis from its Dec. 22, 2022 official publication.
The regime should be read as an AML layer within Brazil’s broader virtual-assets framework. Law No. 14,478 defines virtual assets, identifies the categories of virtual asset services, and requires VASPs to operate under authorization from the federal body designated by the executive branch. Decree No. 11,563/2023 designated Banco Central do Brasil as the authority to regulate, authorize and supervise VASPs, while preserving the Comissão de Valores Mobiliários’ separate authority over securities.
In practical terms, the AML Law supplies the statutory duties and sanctions, while Law No. 14,478 and Banco Central rules supply the virtual-asset perimeter, authorization path and supervisory architecture. The result is a layered regime: VASPs are expressly brought into the AML Law’s list of covered persons, but their operational status and prudential treatment depend on Banco Central implementation.
Key Provisions of Brazil’s AML Regime for VASPs
- Covered persons: Article 9 now includes VASPs among persons subject to the AML Law’s customer identification, recordkeeping and reporting duties.
- Customer identification and records: Article 10 requires covered persons to identify customers, maintain updated registrations and keep records of transactions involving virtual assets above limits set by the competent authority.
- Internal controls: Covered persons must adopt policies, procedures and internal controls compatible with their size and transaction volume, as disciplined by competent authorities.
- Coaf reporting: Article 11 requires attention to potentially suspicious transactions and communications to Coaf or the relevant regulator within the statutory framework, including no-tipping-off language.
- Administrative sanctions: Article 12 provides for warnings, fines, temporary disqualification of administrators, and suspension or cancellation of authorization for covered persons that fail to comply with Articles 10 and 11.
VASP Scope and Regulator Allocation
Law No. 14,478 treats a VASP as a legal entity that performs, on behalf of third parties, at least one virtual asset service, including exchange between virtual assets and fiat currency, exchange between virtual assets, transfers, custody or administration, or services connected to offers or sales of virtual assets. The same law excludes securities-law assets from its general virtual-asset perimeter and states that it does not alter CVM authority.
Banco Central’s implementing framework gives the AML Law practical supervisory context. Resolution BCB No. 519 addresses authorization processes for VASPs and certain financial-market intermediaries. Resolution BCB No. 520 disciplines the constitution and functioning of VASPs, classifying them as intermediaries, custodians or brokers, and includes asset-segregation, proof-of-reserve, outsourcing, information, cybersecurity and monitoring provisions. Resolution BCB No. 521 incorporates specified virtual-asset activities into the foreign-exchange and foreign-capital reporting framework.
Status, Timeline and Implementation Milestones
The original AML Law entered into force on publication in March 1998. The VASP AML amendments were enacted through Law No. 14,478 on Dec. 21, 2022, published on Dec. 22, 2022, and became operative on June 20, 2023. Decree No. 11,563/2023 then allocated supervisory authority to Banco Central. Banco Central’s 2025 implementing resolutions entered largely into force on Feb. 2, 2026, with selected Resolution BCB No. 521 provisions effective May 4, 2026.
For editorial use, this profile should be categorized under Brazil, AML/CFT, Licensing & Registration, Market Structure & Regulatory Perimeter and Custody. It is not a standalone licensing guide or legal advice. It summarizes the public legal framework and should be updated as Banco Central issues or amends implementing regulations, authorization instructions, prudential rules or AML-specific supervisory guidance.