BRAZIL
Brazil: VASP License (BCB Framework)
Brazil has moved into a formal licensing regime for Virtual Asset Service Providers (VASPs), overseen by the Central Bank of Brazil (BCB). The framework introduces defined service modalities, governance and controls expectations, client-asset safeguards, and reporting requirements.
What changed in Brazil
Brazil’s new BCB-led framework introduces an authorization path and clearer expectations for how VASPs operate, protect client assets, and manage cross-border exposure.
Authorization regime
Defined authorization route for VASPs, with ongoing supervision and reporting requirements.
Modalities
Service categories typically align to intermediation (broker/exchange), custody, and brokerage functions.
FX / stablecoin perimeter
Virtual-asset cross-border and fiat-referenced stablecoin activity can fall under FX rules (phased in).
What regulators will expect
A practical checklist of the pillars you should plan for.
Governance & fit-and-proper
Clear management structure, oversight, accountability, and suitability standards for controllers and leaders.
AML/CTF program
KYC, monitoring, SAR workflows, risk assessment, and control documentation aligned to your service scope.
Client-asset safeguards
Segregation, custody controls, reconciliations, and evidence-backed statements on reserves (where applicable).
Capital & financial robustness
Capital expectations vary by activity scope and risk. We plan the route around your model and target volume. Ranging between R$10.8m and R$37.2m.
Engagement options
Choose the level of support based on whether you are a new entrant or transitioning an existing operation.
- Activity mapping (modality + FX perimeter)
- Governance & internal controls blueprint
- AML/CTF policy pack + procedures
- Client asset safeguarding design
- Documentation checklist for authorization pathway
- Gap assessment vs. BCB requirements
- Transition roadmap (phased deliverables)
- Policy and control upgrades
- Reporting readiness + evidence pack
- Operational remediation support
How the engagement works
Remote-friendly delivery from scope to authorization-ready operations.
Model mapping
Define your modality (exchange/broker/custody) and identify FX/stablecoin touchpoints.
Entity & governance plan
Structure local presence, roles, oversight, and control environment aligned to expectations.
Compliance build
AML/CTF program, monitoring approach, client asset safeguards, and incident response playbooks.
Evidence pack & reporting readiness
Policies, procedures, registers, and supporting evidence prepared for the authorization pathway.
Transition support (if applicable)
For incumbents: staged remediation plan and upgrades aligned to the timeline.
FAQ
Quick answers to the most common Brazil questions.
Do I need authorization to operate a crypto exchange in Brazil?
Under the BCB framework, providing virtual-asset services in Brazil generally requires authorization, depending on your activity scope and client-facing operations.
Does this affect stablecoin products?
Certain stablecoin and cross-border virtual-asset activity can fall under Brazil’s FX perimeter, which has phased implementation in 2026.
Can a foreign company serve Brazilian users without a local entity?
Many models will require local structuring and an authorization route. We’ll assess your setup and recommend the cleanest path.
Exploring Brazil?
Message us your model and we’ll send a private readiness overview (modality, FX/stablecoin notes, and a clean next-step plan).
