Executive summary
This page provides an overview of crypto-asset transfer regulation and Travel Rule requirements in Brazil. It is intended for Virtual Asset Service Providers operating locally (known as SPSAVs), financial institutions, and compliance teams interacting with the Brazilian market.
Following the entry into force of Law 14.478/2022 and subsequent Central Bank regulations, Brazil has formally integrated virtual asset activities into its National Financial System. As of 2026, Travel Rule obligations form a core component of this framework, reflecting Brazil’s move toward a highly structured and institution-grade crypto regulatory regime.
This content is provided for informational purposes only and does not constitute legal advice.
Regulatory landscape overview
Brazil’s crypto regulatory framework represents one of the most significant shifts in Latin America, moving from a permissive environment to a central-bank-led supervisory model.
Key characteristics of the Brazilian approach include:
Formal recognition and licensing of SPSAVs under federal law
Centralised supervision by the Central Bank of Brazil
Integration of crypto-asset transfers into foreign-exchange and payment oversight
Progressive implementation of Travel Rule obligations through phased enforcement
The framework aligns with Financial Action Task Force (FATF) standards and reflects Brazil’s emphasis on transparency, financial stability, and systemic risk management.
Supervisory and regulatory authorities
Travel Rule compliance in Brazil is overseen through a coordinated regulatory structure:
Banco Central do Brasil (BCB): Primary supervisor for SPSAV authorisation, AML/CFT oversight, and Travel Rule implementation
Comissão de Valores Mobiliários (CVM): Oversees digital assets classified as securities
Conselho de Controle de Atividades Financeiras (Coaf): National Financial Intelligence Unit receiving suspicious activity reports
This structure places crypto-asset supervision firmly within Brazil’s traditional financial regulatory architecture.
Travel Rule status in Brazil
The Travel Rule is implemented in Brazil through Central Bank regulations, with phased enforcement timelines for domestic and international activity.
Under the Brazilian framework:
Travel Rule obligations apply broadly to virtual asset transactions conducted by licensed SPSAVs
Data collection and transmission requirements apply irrespective of transaction value
Full enforcement is being introduced progressively, with firms expected to align systems ahead of mandatory deadlines
Brazil’s model is among the most expansive globally in terms of scope and supervisory ambition.
Timeline and key milestones
June 2023: Law 14.478/2022 enters into effect
February 2026: BCB Resolutions 519, 520, and 521 come into force; new authorisation regime begins
May 2026: Mandatory reporting of international crypto-fiat operations to the BCB
February 2027: Mandatory Travel Rule compliance for domestic virtual asset transactions
February 2028: Mandatory Travel Rule compliance for international virtual asset transactions
Thresholds and scope
Brazil has adopted a zero-threshold approach to Travel Rule data collection.
Threshold: No de minimis exemption; Travel Rule requirements apply regardless of transaction value
Scope: Applies to exchanges, custodians, brokers, and intermediaries operating as SPSAVs
Cross-border limits: International virtual asset operations may be subject to additional foreign-exchange controls unless specific authorisation is obtained
This approach reflects Brazil’s focus on full transaction traceability and systemic oversight.
Required data elements (high-level)
For in-scope transfers, Brazilian regulations generally require information relating to:
The originator, including identifying details, national identifiers, and wallet information
The beneficiary, including identifying details and wallet or account information
Links between crypto-asset transfers and associated fiat payment accounts, where applicable
Specific data elements are defined in BCB regulations and supporting guidance and must be made available to authorities upon request.
Local nuances and interpretive considerations
Several aspects of the Brazilian framework are particularly relevant for compliance teams:
Foreign-exchange treatment: Crypto-fiat transactions may be treated as FX operations under BCB supervision
Capital and governance requirements: SPSAVs are subject to minimum capital and governance expectations
Asset segregation: Client assets must be clearly segregated from proprietary funds
These features reflect Brazil’s intention to align crypto-asset service providers with traditional financial institutions.
Self-custodied (unhosted) wallet considerations
Brazil applies a highly explicit and technology-forward approach to transfers involving self-custodied wallets.
Identification of counterparties is expected for unhosted wallet interactions
Technological mechanisms may be used to assess wallet control and transaction origin
Enhanced monitoring applies to mitigate obfuscation and illicit activity risks
This places Brazil among the more prescriptive jurisdictions globally in this area.
Cross-border and interoperability considerations
Brazil has acknowledged the operational challenges of global Travel Rule implementation and adopted a phased approach for international activity.
Key considerations include:
Gradual alignment with international messaging standards
Risk-proportionate assessment of foreign counterparties during the transition period
Increased expectations for interoperability ahead of the 2028 enforcement deadline
Internationally active firms must therefore plan for evolving cross-border requirements.
Indicative compliance readiness checklist
The following considerations are illustrative and non-exhaustive:
Appropriate authorisation as an SPSAV with the Central Bank of Brazil
Ability to support zero-threshold Travel Rule data collection
Processes for handling self-custodied wallet transfers
Governance and capital structures are aligned with regulatory expectations
Record-keeping aligned with Brazilian AML retention requirements

